The interplay of succession laws in Europe has always been complex. The EU Succession Regulation has been fully effective since the summer of 2015 and has changed the landscape for succession in most of the EU. Brexit has not changed its impact in the UK or elsewhere and the Regulation affects the estates of any person dying a national of or domiciled in an EU country, or who has previously been resident there or with assets there.
The second edition of this book attempts to look at the subject from the perspective of a practitioner outside the EU, address some of the various topics that may be relevant and attempt to give some answers to the many questions that remain, with an eye to both the novice and the experienced private international lawyer. It has been updated to include all cases from the European Court of Justice up to March 2025. The effects of the Regulation have recently been limited by national legislation and public policy issues particularly in France and Germany. The expanded chapter on public policy addresses these questions in detail.
ABOUT THE AUTHORS
Richard Frimston is a solicitor and consultant with Russell-Cooke LLP in London and former partner and head of their private client group. He advises clients in relation to their estate planning, wills, probate and tax planning issues. He is one of the best-known speakers and writers on the topics of cross border estates and the Regulation.
Jessica Flowerdew is a bi-lingual solicitor and partner with Brodies LLP in Edinburgh. She has particular expertise in UK - French cross border issues and is also a well-known speaker on these topics.