In the case of successions governed by Italian law with elements of internationality and where there are testamentary dispositions requiring implementation and special technical expertise, it may be very useful to appoint an executor of the will He may also perform acts abroad, being able to use the European Certificate of Succession in another [...]
The trust is currently the most modern tool for succession planning in Italy, including for the generational transfer of a company. Revenue Agency Circular 34/2022 confirms that the trust is extraordinarily advantageous from a tax point of view. When owning assets in several countries, it is important to assess the trust from the perspective [...]
In France, there are several types of marital unions: - Free union an informal union (that does not confer inheritance rights) - The civil solidarity pact or PACS, which is a registered partnership (that confer very few rights in the inheritance) - And marriage. They all are available to same-sex couples. The PACS can [...]
The personal representatives ('PRs') are responsible for administering the estate following a death. The PRs will either be appointed under the Will (i.e., executors) or, in the absence of a Will, by the Court. The PR will be responsible for applying for the Grant of Representation (which gives them authority to deal with the [...]
Most European citizens living abroad ignore this fact. In the absence of a formal declaration to the contrary, their succession will be governed by the law of the country in which they reside. This rule, which replaced the old principle based on nationality, was introduced by the European Succession Regulation No. 650/2012, which [...]
Planning through trusts remains the most flexible solution from a UK tax perspective for res non-doms (i.e., foreigners who live in the UK). Such trusts, created before the individual becomes UK deemed domiciled (i.e. before year 16 of UK tax residence) and funded with non-UK situs assets, offer potentially significant UK tax benefits, including [...]
