Jurisdiction(s):
United Kingdom

EU Succession Regulation and French property: applying English private international law, renvoi and Article 22, with UK IHT and French forced heirship issues - case study

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Facts

Antoine and Camille met while both working in Leeds in 1980, and in 1981 they bought a home there in their joint names. They had three children together—Gabriel (born 1985), Audrey (born 1987) and Laure (born 1990)—and married in 1995. In 2003, Antoine inherited a chalet in the French Alps. Throughout their marriage they remained resident in the UK, taking regular trips to France for holidays and to visit family. Camille, born in France in 1955 to French parents, lived there throughout her childhood and early twenties until moving to England in 1979. Antoine, born in England in 1953 to an English father and French mother, grew up in England, but spent five years in the 1970s living with his maternal grandparents in Lyon while at university. Antoine died in April 2024 at the age of 71, leaving both an English Will and a French Will. The French Will includes a declaration that, under Regulation (EU) No 650/2012 (the EU Succession Regulation, also known as Brussels IV), the law of England and Wales is to govern the succession of Antoine’s estate...

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Web page updated on 21/05/2026

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