European Harmonization

Every country1 in the European Union (EU) has its own laws and traditions for inheritances. This presents a problem when someone dies with assets in more than one country, as the conflict of law rules (known as private international law) result in somewhat chaotic treatment. The Hague Conference on Private International Law (Hague Conference) considered the following example: A person dies domiciled

Every country1 in the European Union (EU) has its own laws and traditions for inheritances. This presents a problem when someone dies with assets in more than one country, as the conflict of law rules (known as “private international law”) result in somewhat chaotic treatment. The Hague Conference on Private International Law (Hague Conference) considered the following example:

A person dies domiciled in the Netherlands. Together with his or her Dutch goods, the decedent le

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