Head of French law and property, Russell-Cooke, London
I was encouraged by my father to do a law degree as he felt I stood a better chance of getting a job than with an English degree. Having obtained the qualifying Part 1 exemption during my degree course, it seemed easier to pursue that route than to give serious thought to other options.
Aside from a school A-level my knowledge of French and French law was non-existent and so the thought that I might live and work in France running my own firm as a qualified French-registered avocat and solicitor was not remotely on the horizon.
It was only some years later that I got the chance to live and work in France (I spent 10 years there in the 1990s). There I was able to develop the skills necessary to provide the specialist advice sought by the very large number of individuals (mainly British nationals) with property interests in France. The issues often cut across both English and French law.
I was expected to qualify as a French avocat and to be able to work in France and pass their equivalent entrance exams without any particular exemptions. The civil law legal system had very little in common with the English common law system. But that could only happen when my language capabilities and my knowledge of French law were sufficient to sit the oral exams.
Opening the letter informing me that I would be admitted as a French avocat at the forthcoming admissions ceremony in Bordeaux was unbelievable. I think I was the first foreign lawyer to be admitted to the Bordeaux bar at the time.
It is rewarding to feel I am providing real assistance to clients who can often despair of finding a solution. I never cease to be amazed at the infinite variety of issues where advice is needed. We are now dealing with the practical effects of the new EU Succession Regulation 650/12 which came into force in France in 2015 but where the UK exercised its right of ‘opt-out’. Unfortunately, we do not yet have a rulebook for what this means in practice.
We have a team of Anglo-French lawyers here in London and French is often the day-to-day working language. The crucial difference is the experience of both legal systems and cultures, and the ability to move freely between both. Understanding the cultural references is essential – it is almost never a question of providing a pure ‘legal’ solution.
There are the obvious differences in working in France – titles are important and generally there is a greater emphasis on hierarchy. Meetings are initially more formal and shaking hands is de rigueur.
In France a part of the person’s succession is designated for children under the reserved heirship rules. This is a fundamental principle of French law and is accepted as being protective of the children.