The new rules are contained in regulation (EU) no 650/2012 and came into effect from 16 August 2012. They will apply from 17 August 2015. The UK has opted out of this regulation, though it is of considerable relevance to UK residents and nationals because almost every EU country will apply it. This article sets out the rules and the unanswered questions with respect to the UK and France.
WHY THE RULES MATTER
From now on, people resident in England can, in most cases, provide in their wills that English law is to apply to their estate in France, including French land. Provided this is done correctly, the French notaire will apply the English rules on your death (if you die after 17 August 2015).
This is a fundamental change, as previously French law had always applied to French land regardless of whether the deceased died resident in England. It is sensible to review existing wills.
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