Do you need help collecting UK assets for someone who has died In France ?
The starting point is to appreciate that inheritance laws in France and the UK are entirely different. For example, the inheritance tax system is different ( although the spouse exemption applies to both countries ) in France the beneficiaries are taxed unlike in the UK with the Deceased estate responsible for the payment of taxes. Another difference are the Forced Heirship rules which restrict the right of the Deceased to leave out family members from a will such as Children etc. In France the inheritance process is undertaken by the Notaire with an Act De Notoriete recording details of the Deceased estate.
We frequently assist clients from France who have subsequently left assets in the UK. The procedure to obtain probate in the UK can be complicated as the UK Courts will require evidence as to the procedures followed in France and who according to French law are the persons beneficially entitled as well as who can administer the estate. Typically, the L’acte de notoriete will need to be exhibited to the UK Courts together with a Affidavit of Foreign law setting out the precise procedures followed.