A controversial new law came into force in France on 1 November 2021 to apply, under certain conditions, French forced heirship rules even where a will specifies a foreign legal system should apply. This could have significant consequences for some UK residents with French assets.
Under the law of England and Wales, a testator has free choice as to the recipient(s) of their estate, subject only to limited powers of the court to make provision for a limited class of people in certain circumstances. By contrast, domestic French law puts in place rigid rules as to who may inherit from someone’s estate and in what propo...