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International succession in Luxembourg

For a cross-border succession in Luxembourg, EU Regulation 650/2012 in principle designates the law of the deceased's last habitual residence, unless the law of their nationality has been chosen (professio juris). The Regulation also created the European Certificate of Succession, which makes it easier to exercise rights across the EU. The firm secures both planning and settlement.

In short

For an international estate in Luxembourg, European Regulation 650/2012 in principle designates the law of the deceased's last habitual residence, unless the law of their nationality was chosen (professio juris). It also creates the European Certificate of Succession, which eases the exercise of heirs' rights across the EU.

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Maître Cora Maglo, Avocate à la CourResponsible for legal content: Maître Cora Maglo, Avocate à la Cour, Liste I du Barreau de Luxembourg depuis 2009. · Applicable law: Luxembourg

International succession in Luxembourg: key points at a glance

Fees, timeframes, documents and deliverables
ItemWhat to know
FeesOn a fee quote. Depending on the number of jurisdictions and the complexity of the estate.
Indicative timingVariable depending on the countries involved and the complexity; upstream planning reduces deadlocks.
Documents required
  • Civil status records and any will
  • Inventory of the assets and their location
  • List of the heirs and their residence
Deliverables
  • Analysis of the applicable law
  • Planning advice
  • Coordination of the settlement

As soon as a succession involves a foreign element (residence, assets or heirs abroad), the question of the applicable law becomes central and may upset the heirs' expectations.

Cerno Law Firm anticipates these questions (drafting of dispositions, choice of law) and coordinates the cross-border settlement.

International succession in Luxembourg: when should you call on the firm?

A succession involves several countries (residence, assets, heirs).

The applicable law may differ from the one expected and change the shares.

What happens if you do nothing?

Application of an unanticipated law, conflict between heirs, freezing of assets abroad, double taxation.

Without planning, the succession may follow unfavourable rules.

Our involvement

Determination of the applicable law, advice on the professio juris, obtaining the European Certificate of Succession, and coordination of the settlement.

Liaison with notaries and foreign advisers.

Practice areas

When to call on the firm

  • Plan a succession with assets in several countries.
  • Choose the applicable law (professio juris).
  • Obtain a European Certificate of Succession.
  • Settle a contentious cross-border succession.

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On a fee quote

Depending on the number of jurisdictions and the complexity of the estate.

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FAQ

Frequently asked questions

Which law governs an international succession in Luxembourg?

Under EU Regulation 650/2012, in principle the law of the deceased's last habitual residence, unless the deceased chose the law of their nationality (professio juris).

What is the European Certificate of Succession?

A document created by Regulation 650/2012 that allows heirs and executors to prove their status and exercise their rights in other Member States.

Can you choose the law applicable to your succession?

Yes, you can choose the law of your nationality (professio juris), preferably through a clear testamentary disposition. The firm advises you on this.

Member of

Affiliations & professional networks

  • Barreau de Luxembourg
  • European Immigration Lawyers Network (EILN)
  • Union des Avocats Européens (AEA)
  • Cross Border Advisory Solutions
  • Institut Luxembourgeois des Administrateurs (ILA)
  • Association Luxembourgeoise des Juristes de Droit Bancaire (ALJB)

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Written by Maître Cora Maglo, attorney at law.

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Founded in 2013; Maître Cora Maglo has been admitted to the Luxembourg Bar since 2009

2013
independent firm
2009
at the Bar since 2009
4,7/5
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Expertise & authority

Ongoing review and analysis of Luxembourg and European case law

Avocate à la Cour, List I of the Luxembourg Bar since 2009

Trained at the London School of Economics, formerly at Clifford Chance and Bonn Steichen & Partners

Member of international networks: EILN, AEA, Cross Border Advisory Solutions

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