Succession

Estate planning & inheritance

When a family, its assets and its heirs sit in different countries, two bodies of law collide. There is the private law that decides who inherits, and the tax law that decides what the transfer costs. Getting one right does not fix the other. The EU Succession Regulation lets you choose the law of your nationality to govern succession, but it expressly does not touch tax. Forced-heirship rules in civil-law states can still override a foreign will over locally-sited assets. We are a boutique adviser. We coordinate the specialist counsel, notaries and structures that keep a single plan coherent across all the jurisdictions involved.

Last verified July 2026

What this covers

We map every jurisdiction that could assert a succession or tax claim over the family. That means looking at nationality, residence, domicile and where the assets sit. We identify where those claims conflict before anything gets drafted.
We coordinate coherent multi-jurisdiction wills, typically one per legal system. Revocation clauses and executorship should not collide, and we work through local notaries and solicitors to make sure they do not.
We advise on a choice-of-law election under EU Regulation 650/2012, which lets you elect the law of your nationality to govern succession. We also explain its limits. It binds neither Ireland nor Denmark, and it changes no tax outcome.
We assess forced-heirship exposure in civil-law states, including France, Spain, Italy, Germany, Brazil and others. We also look at the protective mechanisms that can defeat a foreign-law election over local assets, such as France's Article 913 compensatory levy.
We model cross-border estate and inheritance tax exposure. That includes US federal estate tax on US-situs assets held by non-residents and the UK's residence-based IHT regime. We coordinate any relief available under the relevant estate-tax treaty.
We pressure-test whether trusts or private foundations help or hurt your position in each jurisdiction. Several civil-law states do not recognise trusts at all, and they treat forced heirship as a matter of public policy.
We coordinate probate and grants of representation across jurisdictions. This includes the European Certificate of Succession, used when an EU-sited asset must be released to heirs.
We convene specialist tax counsel, notaries and trustees. We keep the plan under review as residence, applicable law and thresholds change.

Scope & conditions

EU Succession Regulation 650/2012: Lets an individual elect the law of a State of their nationality (held at the time of the choice or at death) to govern the whole succession. Applies across the EU except Ireland and Denmark, and does not bind the UK. It governs civil succession only, and expressly does not affect any inheritance or estate tax.
Forced heirship (civil law): France reserves a fixed share for children: one-half for one child, two-thirds for two, three-quarters for three or more. Spain reserves two-thirds for children (one-third split equally, one-third at the parent's discretion), with a spousal life interest. Common to France, Spain, Italy, Germany, Switzerland, Brazil and Japan.
France, Article 913 (from 1 Nov 2021): A compensatory levy (prelevement compensatoire) lets a disinherited child recover their reserved share from French-situs assets where the deceased or a child is an EU national or resident and the chosen foreign law offers no equivalent protection. A French Court of Appeal upheld the mechanism in November 2025 (as of 2026, still being litigated, confirm).
United States, estate tax on non-residents: US-situs assets above a USD 60,000 exemption are taxed at rates up to 40% (18 to 40%); the exemption is not inflation-indexed. US corporate stock and US real estate are situs assets; non-business US bank deposits, portfolio-interest debt and most life-insurance proceeds are not. Form 706-NA is due within nine months of death. Contrast the USD 15m exemption for US domiciliaries from 2026.
United Kingdom, IHT residence basis (from 6 Apr 2025): Domicile was replaced by residence. Worldwide assets fall within IHT once a person is a long-term resident, meaning UK-resident for at least 10 of the previous 20 tax years; a three-to-ten-year tail keeps leavers in scope after departure. Rate is 40% above the GBP 325,000 nil-rate band (plus up to GBP 175,000 residence nil-rate band), frozen to April 2030 (Autumn Budget extended the freeze to April 2031, confirm).
US estate-tax treaties: The US has estate/gift-tax treaties with roughly 15 countries, including the UK, France and Germany (confirm against the IRS list). The US-UK convention, in force since 1980, can give a UK-resident estate the full US unified exemption in place of USD 60,000, and its tie-breaker (permanent home, centre of vital interests, habitual abode, nationality) fixes primary taxing rights.
European Certificate of Succession: A standardised EU instrument, recognised automatically across bound member states without exequatur, proving heir, legatee or executor status to banks and registries. It does not apply in Ireland or Denmark, or outside the EU, and does not fully replace national documents.

How it works

We begin from documents. That means current wills, a marriage or PACS contract and matrimonial-property regime, a schedule of assets by jurisdiction and legal title, and each family member's nationalities and tax-residence history.
A choice-of-law election under Regulation 650/2012 must be made expressly, normally within a will. It should be revisited whenever nationality, residence or the will itself changes.
Multi-jurisdiction wills are drafted in concert, so that revocation clauses and executor appointments do not conflict. Formal validity, meaning witnessing, notarisation and language, is verified in each place.
Tax and succession are analysed separately for each jurisdiction. A valid succession plan can still leave a large estate-tax charge, and a tax-efficient structure can still breach heirship rules. Any treaty relief must be claimed within the deadline. For the US, that means Form 706-NA within nine months of death.
Structures such as trusts, foundations or holding companies are tested against local recognition and forced-heirship public policy before assets are moved, not after.

What can go wrong

We are a boutique firm. We do not draft foreign wills ourselves, issue legal opinions on foreign law, or file tax returns. Instead, we coordinate qualified local counsel, notaries and tax advisers, and we stay accountable for making sure the plan holds together.
Every threshold here is a legal fact as at 2026, and any of them can change. The UK switched from domicile to residence in April 2025. US exemptions changed in 2026. France's Article 913 is under active litigation. We confirm each figure against primary sources before you rely on it.
Electing your national law under Regulation 650/2012 does not stop a civil-law state from applying forced-heirship protection to locally-sited assets. It also changes no tax outcome. Succession and tax run on separate rules.
We do not quote our own fees on this page. Scope and cost are set out in a written engagement after an initial consultation, and specialist counsel bill separately.
Nothing here is legal or tax advice for your circumstances. Cross-border succession depends on facts we would need to review with you directly.

Frequently asked

Does choosing my national law under EU Regulation 650/2012 also cut inheritance tax?

No. The Regulation lets you elect the law of a country of your nationality to govern who inherits, but it expressly excludes taxation. Estate and inheritance tax are decided separately, under each country's own rules on residence, domicile and asset situs. The election also does not bind Ireland or Denmark, since both sit outside the Regulation.

Can I disinherit my children if I own property in France?

Rarely in full. France reserves a fixed share for children: one-half for one child, two-thirds for two, three-quarters for three or more. Since 1 November 2021, Article 913 also lets a child recover their reserved share from French-situs assets where the deceased or a child is an EU national or resident and the chosen foreign law offers no equivalent protection. A French appeal court upheld this mechanism in November 2025, though it is worth confirming since the point is still being litigated.

I am not American. Will the US tax my estate on my US shares and property?

Potentially, yes. A non-resident, non-citizen is subject to US federal estate tax on US-situs assets above just USD 60,000, at rates up to 40%. US company shares and US real estate count as situs assets. Non-business US bank deposits and portfolio-interest bonds generally do not. Form 706-NA is due within nine months of death, and a relevant estate-tax treaty, for example US-UK, may substitute a far larger exemption.

How did UK inheritance tax change for non-doms in April 2025?

From 6 April 2025 the UK replaced domicile with residence as the test for inheritance tax. You become exposed to IHT on worldwide assets once you are a long-term resident. That means UK-resident for at least 10 of the previous 20 tax years. A three-to-ten-year tail keeps you in scope even after you leave. The rate is 40% above the GBP 325,000 nil-rate band, and that band is frozen to at least April 2030.

Do I need a separate will for each country where I own assets?

Often, yes. Separate but coordinated wills, one for each legal system, usually speed up probate and cut down on translation and recognition problems. They need to be drafted together, though, so that one does not accidentally revoke another. Where an EU-sited asset needs to be released, a European Certificate of Succession can prove an heir's or executor's authority across bound member states, without a separate recognition step.

Will a trust protect assets from forced heirship?

Not reliably, not in civil-law countries. Several, France among them, do not recognise trusts at all and treat forced heirship as a matter of public policy. That means a local court may simply disregard the trust for assets sited there. Foundations or holding structures sometimes travel better, but each one has to be tested against local law before any assets are moved.

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