Question: went to the bank for some basic investment advice. Bottom line: Napoleonic code applies and children will get half, surviving spouse gets half. Whichever way it’s split . Now, it’s not that I don’t like the offspring, but I prefer the british or/ and german system. For obvious reasons of independence and a dozen more. I appreciate that the house is under french law, but what about our pensions and investments in the uk and Germany? Is there a way to arrange things?
If you are British you can choose to write your under the law of UK or France. So if you choose UK law then you can leave everything to the home for endangered cockroaches if you wish - but they still will have to pay French inheritance tax which is eye-watering!
Google Brussels IV and all will be revealed.
brilliant!!! As ever, you are an endless and amazing source of information. Our wills, which we have redone when we got here, are in english and as simple as can be. Loosely translated from german: we nominate the spouse as sole beneficiary of all assets and posessions whether they are held in the UK, Germany or France. Is there a threshold for taxfree as there is in UK and Germany?
Hmmmmmm. Homes for endangered cockroaches. Is it a sanctuary for ex populists perchance? You know, ones with cute names like Donald, Reccep, Vlad and Boris?
If you have children you need to state very clearly that you wish your wills to be under UK law. Otherwise the law of the country of your residence will apply and the kids will get their proportion. There is a form of words that we used that I will find later if no one else pops up with it.
We have opted just to have wills in english under english law. Often people have different opinions and feel you should have both but our lawyer said no.
Yup, you got it! Best to keep them under lock and key…
Man, I am so glad of that British nationality now! I dithered a mere 34 years…