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In an effort to deal with cross border inheritance issues, a new EU law came into effect in August 2015.

Most EU countries have adopted this new law, with the noticeable exception of the UK.  However, despite the UK opting out of the new regime, you may still be able to use its legislation to your advantage.

Under the new EU system, the law of only one country can apply to the succession of your estate throughout the EU.  The definition of which country that will be is:

(i)       The country in which you are resident when you die UNLESS
(ii)       You are more closely connected with another country and
(iii)      You elect for the law of your national country to apply.

To ensure that your worldwide assets are administered in accordance with UK law (and not some state system dating back to the Romans), you need to add a reference to the new legislation to your Will(s).

We recommend discussing the changes with your legal advisers, however if you want to know more please get in touch on our usual numbers.


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