Q&As

If a UK national testator, domiciled in Italy under English law, dies leaving movable assets in the UK, having made a valid English Will that deals with worldwide assets including a choice of law clause for the law of England and Wales to apply to the succession of their estate as a whole, will the English court apply Italian succession law or English succession law to those UK situs movable assets?

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Published on LexisPSL on 25/09/2020

The following Private Client Q&A provides comprehensive and up to date legal information covering:

  • If a UK national testator, domiciled in Italy under English law, dies leaving movable assets in the UK, having made a valid English Will that deals with worldwide assets including a choice of law clause for the law of England and Wales to apply to the succession of their estate as a whole, will the English court apply Italian succession law or English succession law to those UK situs movable assets?

Based on the information set out in this Q&A, the EU Succession Regulation (Regulation), Regulation (EU) No 650/2012 is relevant in determining the succession to the testator’s movable property in the UK. For information on the Regulation (EU) No 650/2012 and its application to the UK, see Practice Note: Will drafting—applying the EU Succession Regulation.

In deciding which law applies, the following poin

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