We offer high-quality specialist advice on many cross-border legal matters including:
- international estate and tax planning
- cross-border wills and matrimonial and inheritance contracts
- care and protection of the elderly and their assets across national borders
- obtaining UK Grants of Probate for persons who die outside the UK
Estate and tax planning
International and cross-border estate and tax planning is highly complex. Many other advisers can help on UK estate and tax planning for non-domiciled residents. However, often the effect of such planning in other jurisdictions is ignored. We have developed considerable expertise in understanding and advising on the estate and tax effects not only in the UK, France and Italy but also in other EU states, the USA, India and many other states.
Cross-border wills and matrimonial and inheritance contracts
We have excellent experience in assisting both non-UK persons who want to ensure the succession to their UK assets only, and those UK individuals who simply have a holiday home abroad and want to control its succession. We have in-depth knowledge of the effects of the EU Succession Regulation (Brussels IV). In addition we can also advise on foreign matrimonial property regimes and their effect in the UK, a topic which is often overlooked.
Care and protection of the elderly
Issues surrounding care and protection of the elderly in cross-border situations can become very complex. Certain members of the team are experts in this field and, by working together with our family and children teams, we can ensure that we provide co-ordinated advice.
Obtaining UK Grants of Probate
The process of obtaining a Grant of Probate for a person dying outside the UK can be a complicated affair, particularly for those who are more familiar with other systems of law. We have significant expertise not only in obtaining UK Grants of Probate for those who died domiciled outside the UK, but also in re-sealing Grants from other jurisdictions. We can also advise on the admissibility of non-UK equivalents to Grants of Probate, such as certificates of inheritance, erbscheins, or European Certificates of Succession.
The team includes Dutch, French and Italian speakers and has considerable experience dealing with cross-border matters. The majority of the team are active members of STEP (Society of Trust and Estate Practitioners), a body with an international reach, and the team is supported in particular by the French qualified lawyers within the firm.