Europe.

Europe is the most legally integrated of the four regions. EU Succession Regulation 650/2012 (Brussels IV) — applicable in 25 EU Member States since 17 August 2015 — provides a single law of succession (the law of the decedent’s habitual residence), an optional choice-of-law in favour of the law of nationality, and the European Certificate of Succession recognized across participating Member States.

The United Kingdom, Ireland, Denmark, and Switzerland sit outside Brussels IV. Switzerland and Liechtenstein operate on their own private-international-law frameworks. Forced heirship is the dominant pattern across the region — réserve héréditaire in France, Pflichtteil in Germany and Austria, legítima in Spain and Portugal, riserva in Italy — with the UK and Ireland representing notable common-law exceptions modified by family-provision legislation.

• Brussels IV (EU Succession Regulation 650/2012) — habitual residence as default; professio iuris for nationality election.
• Forced heirship across most jurisdictions, with the UK’s testamentary freedom as a notable exception.
• High inheritance-tax rates in some countries (France, Germany, UK at top brackets) versus zero in Liechtenstein and Switzerland (federal level).
• Estate-tax treaties with Canada do not exist — only the UK has an estate treaty with the US, not with Canada.
• Matrimonial property regimes shaped by the EU Matrimonial Property Regulation 2016/1103.
• Trust recognition under the Hague Trusts Convention 1985 — important for civil-law jurisdictions hosting common-law trust assets.
• The post-Brexit UK long-term-resident regime (FA 2025/2026) replacing domicile-based IHT exposure.
• Switzerland’s federal-cantonal split and the 2025 rejection of the JUSO 50% federal inheritance-tax initiative.