The EU estimates that more than 450,000 cross-border estate administrations take place in the union every year. It puts the combined value of these estates at more than €120-billion (R1.8-trillion). Estates with cross-border elements are usually characterised by their high complexity because, throughout Europe and the rest of the world, private international law rules that determine succession can vary considerably. Many countries in the EU, such as France, Spain, Portugal, Germany and Italy, have "forced heirship" rules, which can potentially provide statutory or fixed shares to certain family members and restrict testamentary freedom. So, in some cases, a South African with assets in certain countries in Europe may be restricted as to who they can gift their assets. However, where a South African owns assets in the EU (apart from the UK, Ireland and Denmark), the European Succession Regulation, also known as Brussels IV, presents a useful planning opportunity as you can choose for...

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