Renvoi and Conflict of Laws

Renvoi and Titleconflict of laws date Zoé AncelText -Lioger Responsible of the Department Private International Law and Comparative Law CRIDON of Lyon

The contentThe content of this of this document document represents represents the the views views of the authorauthor only only and and it isit his/heris his/her sole sole responsibility. responsibility. The EuropeanThe European Commission Commission does does not not accept accept any any responsibility responsibility forfor useuse that that may may be be made madeof theof the information information it contains. it contains. Intestate succession (renvoi)

Art. 21 Law of last habitual residence

Law of a Member State Law of a third State

 Application of internal provisions Consultation of foreign conflict-of-laws rules Accepts its jurisdiction = European Union except Denmark, renvoi to renvoi to  Application of internal the United Kingdom, and Ireland provisions Law of a Member State Law of a third State

= renvoi at first instance  consultation of OK foreign conflict-of-law = European Union rules except Denmark, UK & Ireland The law of this third State The law of accepts its jurisdiction another State OK

Article 21 Article 22

 Law of the last  National law habitual residence "broad choice of law"

Disposition of property upon death

Will Agreement as to succession article 24 article 25 substantive validity substantive validity = expected succession law = expected succession law  of the testator's residence (art. 21)  of the residence of the person involved (art. 21)  of the nationality (art. 22)  of the national law of one of the persons "limited choice of law" involved (art. 22) "limited choice of law"