Which law applies?
Can I choose the law applicable to my succession?
Last update: 10/1/2012
The succession is governed by the law of the state in which the deceased had his/her ‘domicile’ at the time of his/her death. It is important not to confuse this notion with that of ‘domicile’ within the meaning of the legal systems of continental Europe, as well as the concept of ‘nationality’. According to common law, the actual residence of a person is less important; what is decisive, however, in connection with a certain legal system.
However, the succession in real property (immovable property) is governed by the law of the state in which the respective land parcel is situated. The testator cannot choose the law applicable to the succession.
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Successions in Ireland
Current country: Germany