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Learn more here. Close Me. Last Updated: 9 August Relevance of the Regulation for Swiss Estate Planning?
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While Switzerland is not an EU Member State, the Regulation will affect estates of persons residing in Switzerland and Swiss nationals living in an EU Member State in the following cases: if the deceased person was a Swiss national and had his last habitual residence in an EU Member State; if the deceased person was an EU national who had his last habitual residence in Switzerland and who made a choice of law in favor of his EU national law; or if the deceased person was residing in Switzerland and leaves assets in an EU Member State.
Key Rules regarding Jurisdiction and Applicable Law The "Last Habitual Residence" as the General Connecting Factor in EU Cross-border Succession Under the Regulation, the courts of the Member State where the deceased had his last habitual residence have jurisdiction with regard to the entire estate, thereby applying the inheritance law of that state.
Rules on Subsidiary Jurisdiction In cases where the deceased had no residence in an EU Member State but left assets in such state, the respective EU Member State has jurisdiction to rule on the succession as a whole if i the deceased had the nationality of that Member State at the time of death; or, failing that, ii the deceased had his previous habitual residence in the respective Member State, provided that, at the time the court is seized, a period of not more than five years has elapsed since the habitual residence changed.
Subsidiary Rules on the Applicable Law Closer Connection with Another State With respect to the general rule for the determination of the applicable law, the Regulation provides for an exception if the deceased, at the time of death, was manifestly closer connected with a state other than the state of his last habitual residence. Choice of Law The Regulation provides for a limited choice of law possibility: Testators may subject their estate to their national law at the time of making the choice or at the time of death.
Jurisdiction in Case of a Choice of Law In the event that the deceased has made a choice of law in favor of a Member State, the regulation allows the parties heirs, legatees to agree that a court or the courts of that Member State shall have exclusive jurisdiction to rule on any succession matter. Certificate of Succession A new European certificate of succession should facilitate the recognition of the heirs.
Need for Succession Planning? Conclusion By providing uniform rules on jurisdiction and the applicable inheritance law, the Regulation will facilitate EU cross-border successions and brings significant improvement for the heirs of an EU cross-border estate. Do you have a Question or Comment? Interested in the next Webinar on this Topic?
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More from this Author. Daniel Leu. Sandra Spirig. EU Succession Regulation. Probate Grief Tax Dropped. Justice Secretary Robert Buckland recently announced that the government has dropped its plans to introduce a scaled probate fee first proposed in It is an extreme, yet salutary, lesson that Something is changing in Italy.
watch Italian legislation concerning successions and marriages, which has always been resistant to reforms, could undergo major changes. With the entry into force of the Italian Legislative Decree no. Italian trust fund and family trust: what are the differences between them? What is meant with revocation? You can find all answers and other information here.
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