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Post by Admin on Nov 17, 2015 13:32:39 GMT 1
e-justice.europa.eu/content_successions-166-en.do?init=trueNational rules on inheritance vary considerably between Member States (as to who inherits, what the portions and reserved shares are, how wide the testamentary freedom is, how the estate is to be administered, how wide the heirs' liability of debts is, etc.). In cross-border inheritance cases, it is imperative to determine which court has jurisdiction to deal with the case and which law applies to the case.
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Post by littlemouse on Nov 17, 2015 15:09:57 GMT 1
almost at the bottom of the article is this.
Denmark, Ireland and the United Kingdom do not participate in the Regulation. As a result, succession procedures handled by the authorities of these three Member States will continue to be governed by national rules.
I wonder why these countries won't participate.
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