The Johnny Hallyday case has been making headlines for several months now: who will inherit his fortune? Laeticia or Laura and David? In the United States, it is possible to disinherit one’s children, unlike in France. What inheritance law should be applied? That is the question.
In inheritance law, the country of residence of the deceased will be the element to consider. Depending on the country’s legislation, the inheritance will be either entirely within its jurisdiction, or only in terms of property located in the country, or the responsibility of the deceased’s country of origin.
The law in force in the respective countries will therefore be applied. We therefore recommend that you plan your steps by informing yourself about the inheritance measures applicable to foreigners in your country of residence. Our specialist lawyers can take care of this for you.
Is there any room for maneuver?
This will depend on the legislation of the country of residence, but in some cases, yes! It is quite possible to determine the competent authority and the applicable law in your will or inheritance agreement.
Switzerland accepts appointments from its nationals. It remains to be verified that the country of residence of the deceased authorizes this.
It is also unlikely that you can give jurisdiction to a “random” country, in which you have never lived, just to take advantage of its inheritance law 😉
If you need more specific information, a Lawrence Lawyer can take charge of your estate and assist you in drafting your will.
Be prepared! It’s never too early to think about your will, as this article explains.