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T Perrin C
T Perrin C, Consultant: information en droit du travail
Category: French Law
Satisfied Customers: 1412
Experience:  8 years as a Senior judge at Paris Conseil de Prud'hommes (Paris Industrial Tribunal)
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Below is a query addressed to the EUs Your Europe Advice about

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Below is a query addressed to the EU's Your Europe Advice about the new inheritance law which is self-explanatory. Please could you let me know your opinion on this important matter.

'Thank you for your reply about the new inheritance law that comes into effect on August 17th 2015. There is one crucial point on which there seems to be a difference of legal opinion and I would like your response to this point. For example, on the web site XXXXX XXXXX who is a solicitor advocate writes as follows:
"An English person who dies resident in France and stipulates that English law is to apply to his entire estate will have his French estate administered according to English law. This is because even though the UK has opted out of the regulation, any law can be chosen (article 20) and that must therefore include EU countries which have opted out."
Clearly this is in flat contradiction to your view (Your Europe Advice) expressed in your email reply to me that says: "for now the UK Government has decided not to sign up to this EU Regulation. This means that you cannot elect to have UK law apply to your inheritance."

When you wrote this were you aware of the implications of article 20 of the regulations as XXXXX XXXXX points out? Can you please clarify this important matter for me?'
Although I am not the expert who answered your initial question, I believe I can help you clarify this. This "unicity of law" EU regulation has a universal scope, and is to apply even to citizens of countries which do not belong to the EU (for ex, an AustralXXXXX XXXXXving in France can opt to have Australian law apply to his entire estate), but makes exception for countries which expressly opted out, namely: the United Kingdom, Denmark, Ireland, Switzerland and the United States. In which case the old system will remain in force.
Customer: replied 4 years ago.

So you are saying that the change in regulations due to come into force on August 17th 2015 giving the right to choose the law which applies to inheritance will neither apply to English people who have property in France ( but do not necessarily live there) and wish to opt for English law for the administration of their will nor for French people who have property in England and who wish to opt for French law.

Unless the United Kingdom revises its position, it is unfortunately the case.
T Perrin C and other French Law Specialists are ready to help you
Customer: replied 4 years ago.

Not yet but I will get in touch with the website who are under the impression that the new law will be applicable to English people with property in France and let you know what they say. Hasta pronto