Different countries have their own laws when it comes to dealing with assets on death and sometimes these conflict with each other.
For example, some countries such as Spain and Germany don’t recognise the concept of a personal representative or estate administration. In these jurisdictions, there is no executor to administer the estate, which is what happens in the UK. Instead, when someone dies, the heirs usually appear before a notary to accept the inheritance directly.
Different countries recognise different concepts which influence succession to the deceased’s assets. The concept of forced heirship applies in France and Germany. In these countries specific parts of the estate have to pass to particular beneficiaries - usually the surviving spouse or children – even if this goes against the will.
The interconnection between different legal concepts is complex. That’s why you need to appoint an advisor with specialist knowledge of the succession rules of each country and how they interact with each other to clarify and understand how they affect your unique circumstances.