Trusts and Estates > Estate Planning > European Harmonization

Nov 1, 2010 12:00 PM

European Harmonization

Will Brussels IV succeed?

By Barbara R. Hauser

Every country1 in the European Union (EU) has its own laws and traditions for inheritances. This presents a problem when someone dies with assets in more than one country, as the conflict of law rules (known as “private international law”) result in somewhat chaotic treatment. The Hague Conference on Private International Law (Hague Conference) considered the following example:

A person dies domiciled in the Netherlands. Together with his or her Dutch goods, the decedent leaves a building in England, a bank account in France and a trunk in a Swiss bank. The Dutch court may have jurisdiction on the basis of the decedent's domicile. Jurisdiction may be exercised regarding the entire succession, while an English judge probably has jurisdiction only concerning the liquidation of the English building. In France, a judge could make a decision because of the nationality of one of the parties…2

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