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English Will

Posted by Annmarie-10041119 - Created: 3 years ago
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8 replies (Showing replies: 1 to 8)

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Posted by noblesse-404553 - 3 years ago

Kernowboy,

You can only bequeath your French property under an English will if you are resident in France.

I know, it's not logical, but that's the way it is.

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Posted by Kernowboy-10061199 - 3 years ago

Jake, I think you are mistaken there, the law has recently been changed and you can now register an English will in France, English inheritance rules will be applied although French inheritance taxes will still apply.

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Posted by brionybob - 3 years ago

We have the same situation and we have 2 wills. The English one deals with the English assets and the French is identical but can be used to sort out the holiday home. You need to ensure that the English will does not negate the French one, any solicitor can do English one. Notaire does French one

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Posted by jake-385069 - 3 years ago

English wills are not worth the paper they are written on,French succession law will apply unless the property was declared and bought In Tontine at the time of purchase.

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Posted by Kanak - 3 years ago

certainly possible from this direction but did UK ever sign up to Brusels IV ?,  otherwise default position is french law on property here.  Best to check.

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Posted by countrydweller - 3 years ago

Yes get proper legal and taxation advice there are plenty of UK solicitors who deal with French law and taxation.

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Posted by Kanak - 3 years ago

the possibility is there, but the consequences will be far reaching unless you get a notaire or someone who really understands french napoleonic system to tell you what the tax implications will be.

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Posted by Yellowperill - 3 years ago

Yes most definatley, as your resident in the UK your will and estate will be handled under UK law, its now possible to have your will handled under UK law even if your resident in France we have just set ours up that way with our Notaire