Published On Jun 7, 2021
German probate lawyer and international estate planning expert Bernhard Schmeilzl, Esq., explains whether a Last Will and Testament which was set up in the USA is valid in Europe and whether its content is recognised abroad. The short answer is: Within Europe, foreign wills are usually recognised if they comply with the laws of the country where they have been drafted or the country of which the testator is a national of, see Article 27 of the EU Succession Regulation, which applies in most European countries. The full text of the regulation in English language is available here: https://eur-lex.europa.eu/legal-conte...
More on the international recognition of foreign wills on
https://internationalprobatelaw.com/
and on the specialist law blog Cross Channel Lawyers:
https://www.crosschannellawyers.co.uk/
https://www.crosschannellawyers.co.uk...
You can find the German lawyers of Graf & Partners LLP on this website:
https://www.grafpartner.com/en-gb/home
Have a great day!
Bernhard Schmeilzl, Esq.
German Attorney at Law (Munich)