Useful roadmap for cross-border challenges

This is a concise introduction to an area of practice that many private client solicitors will encounter a few times in their career but may not deal with regularly. As someone who specialises in cross-border succession matters, I am probably not the target audience. But I can see its value for practitioners looking for a practical overview of the issues that can arise when estates span multiple jurisdictions. 

I found myself nodding along to many of the scenarios described, having encountered similar issues in practice. I particularly appreciated the author’s pragmatic approach.

The discussion of domicile is particularly helpful and, at a time when the newly introduced ‘long- term residence’ test dominates much of the legal conversation, serves as a timely reminder of the continuing importance of a concept that remains central to international estate work. I also particularly enjoyed the final chapter on probate applications, which contains several practical pointers for matters with an overseas aspect. Equally welcome was the discussion of the special inheritance tax regime applicable under the pre-1975 double taxation agreements.

Throughout the book, the author emphasises the limits of any general guide in this area. She regularly reminds readers that international estate matters often require specialist advice and collaboration with lawyers qualified in the relevant foreign jurisdiction.

The book works best as a roadmap, identifying the issues practitioners should think about and the questions they should ask when international elements arise. Given the breadth of the subject matter covered, some topics are necessarily dealt with at a relatively high level. Readers looking for detailed analysis of complex cross-border succession issues will need to look beyond this introductory text. However, that is not really the book’s purpose.

Overall, this is an accessible and practical starting point for private client practitioners who want to develop their understanding of international estates, identify potential pitfalls and recognise when specialist input may be required.

Léa Maynard is a senior associate and head of the French team at Buckles Solicitors, Peterborough