Different states have had completely different private international law rules (PIL) for succession. The Succession Regulation (EU) No 650/2012 (SR) has attempted to harmonise PIL for succession throughout the EU without having too significant effect on the internal succession laws of EU Member States. The SR entered into force on 17 August 2012, although most of it will not become fully effective until 17 August 2015.
Richard Frimston, partner and head of the private client group, considers the choice of law provisions.
This article was first published in STEP Singapore, December 2014."
EU Succession Regulation - STEP Singapore - December 2014.pdf