Cross-border succession in the EU isn’t always straightforward. Even with Regulation (EU) No 650/2012 providing clarity on jurisdiction and applicable law, national forced heirship rules can significantly limit testamentary freedom.

Key points to know:

• Forced heirship reserves a fixed portion of an estate for close relatives, affecting how assets can be distributed.
• The scope of these rules varies widely across Member States – from strict regimes in France, Spain, and Italy to more flexible approaches in Germany, Latvia, and Nordic countries.
• Individuals can mitigate risks by choosing the law of their nationality, but careful planning is essential.

Understanding these rules is crucial for reducing disputes and ensuring your succession wishes are respected across borders.

More information here.