Planning across borders: Managing the impact of forced-heirship laws

This STEP webinar brought together cross-border succession specialists to walk through practical solutions for clients with assets and ties in multiple jurisdictions. Using a detailed case study (a dual German-UK national resident in Germany with property and accounts across Europe, the UAE and the U.S.), the panel explained how different legal regimes interact and where common conflicts arise.

Key points

• Identify which law governs the whole succession (habitual residence under the EU Succession Regulation) and whether a choice-of-law is available or likely to be challenged as incompatible with local public policy.

• Forced-heirship regimes vary: Germany’s compulsory-share rules, France’s réserve légale, U.S. state law differences, and Gulf-region frameworks (UAE/DIFC/ADGM) each create distinct risks and planning constraints.

• Practical tools discussed: notarised waivers where permitted, carefully timed lifetime gifts (watch the statutory look-back periods), separate wills or trust structures for immovable U.S. property, and context-specific use of foundations or trusts in DIFC/ADGM to create protective firewalls.

• The technical and tax consequences differ by jurisdiction — coordinate civil-law succession planning with tax and property steps in each relevant forum.

You can access the webinar recording here...

You can access the speaker slides here...