National succession laws in comparative perspective

The 2012 EU Regulation on Cross-Border Successions allows EU citizens to choose between at least two possible applicable laws to their succession: the law of their country of residence or the law of their nationality. This paper aims to highlight how substantive succession law issues are treated in a diverse manner throughout Europe and thus increase the need for proactive estate planning when the choice of law is open to the European resident. In particular, the paper provides a pan-European panorama of the national legal rules on successions, forced heirship rights and, the means of transferring the estat