Regardless of whether the deceased persons were emigrants living abroad, “medical care tourists” (Pflegetouristen), and/or pensioners living abroad, a German married couple which has executed a Berlin Will in Germany and then moves its “usual residence” abroad can no (longer) safely presume that the expressed intent will also be recognized by other countries, at least if a “foreign estate” (Auslandsnachlass) is involved.German couples who have drafted a joint will and subsequently moved their usual residence abroad should inform themselves in a timely manner and, if necessary, make a correction to ensure the effectiveness of the testamentary disposal in the event of their death.New EU Inheritance Law: Are Previously Drafted Wills of Married Couples Invalid?For example: A German couple which has chosen Spain as its permanent place of residence and primarily resides there during the year, has the possibility to apply the so-called “Berlin Will” drafted prior to the new regulation taking effect. Also, the regulation provides for the jurisdiction, the recognition and execution of judicial decisions as well as the acceptance and execution of authentic deeds and judicial settlements. The revocation of a will after 17 August 2015 may have undesired adverse consequences if you, by doing so, also revoke a choice of law that cannot be made after that date.The regulation, which has been adopted by all EU Member States with the exception of Denmark, Ireland and the United Kingdom, provides uniform IPR rules for succession law. Firstly, the regulation only applies to the legal successors of persons deceased on 17 August 2015 or thereafter. Interestingly, Brussels IV does not restrict the choice of law to EU nationals so, for example, a US national with property in a participating EU State could elect for US law to apply to the succession of their property; an Australian could nominate Australian law; a Canadian, Canadian law, and so on.For example, if you are a UK citizen with a holiday home in Italy, you can update your UK Will to cover the Italian property with an election for UK law to apply, instead of having a separate Italian Will for your holiday home. Individuals have a certain degree of freedom in making a choice of law. Action should be taken now to benefit from the new 2015 European Inheritance Rules. May 24, 2015. iExpats aims to help expats make their money work harder by providing the latest financial news from around the worldSpanish taxes depend on how long a home is owned and where the beneficiaries live, as each autonomous community has the right to levy inheritance tax and the rules vary from one region to another.Many could find that if they want to leave a home and other assets in Spain to family or loved ones in the UK that inheritance tax is due in Spain.Spain is the number one expat retirement destinations for the British, with thousands moving to the Mediterranean country each year.Other complicated local rules determine who pays how much tax.So what does this mean for British expats in Spain?Cross-border estate planning between the UK and Spain is so complicated that advice should be taken in each country to make sure any wills comply with tax and succession laws.But few realise that inheritance laws are different from those in the UK – and are about to change.If expats have assets, especially property, in both the UK and Spain, they need to consider making a will in each country to ensure the right heirs receive the property and minimise any taxes due.Succession tax is payable if the inherited asset – including a pension fund – is in Spain if the heir lives overseas or on overseas assets if they live in Spain. Overseas property affected by change to inheritance law Rules designed to allow national laws be applied to succession assets elsewhere in EU Tue, Aug 18, 2015, 01:00
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