ERA Conference on Cross Border Succession
The Academy of European Law (ERA) will host a conference on Planning Cross-Border Succession in Trier, Germany, on March 20 and 21, 2014.
Thursday, 20 March 2014
I. THE SUCCESSION REGULATION
Chair: Christian Hertel
09:15 Scope of application and international conventions that take precedence over the Regulation (Guillermo Palao Moreno)
09:45 Discussion
10:00 Which court is competent to decide cross-border succession cases? Which law is to be applied? (Jonathan Harris)
10:45 – 11:00 Discussion
Chair: Jonathan Harris
11:30 Effects of foreign decisions and authentic instruments in matters of succession
12:00 European Certificate of Succession: conditions for issue of certificate and effects (Christian Hertel)
12:30 – 12:45 Discussion
II. CROSS-BORDER INHERITANCE TAX ISSUES
Chair: Patrick Delas
14:00 Inheritance taxation in the context of EU law (Nathalie Weber-Frisch)
- National inheritance laws in comparative perspective
- CJEU case law on the impact of free movement on inheritance
14:45 Discussion
15:00 Possible measures to avoid double taxation in cross-border successions (Niamh Carmody)
15:30 Discussion
15:45 WORKSHOP (with tea & coffee)
Drafting testamentary dispositions in the light of the Succession Regulation and diverging tax regimes (Patrick Delas & Richard Frimston)
16:45 – 17:30 Results of the workshop and discussion
Friday, 21 March 2014
III. INTERPLAY WITH OTHER AREAS OF LAW
Chair: Richard Frimston
09:15 The impact of matrimonial property on succession law (Patrick Wautelet)
09:45 Discussion
10:00 Company law, trusts and succession disputes (Paul Matthews)
10:30 – 10:45 Discussion
11:15 Proof of succession in land registration proceedings (Kurt Lechner)
11:45 Discussion
Chair: Kurt Lechner
12:00 Inheritance of (holiday) houses and bank accounts abroad: national reports
- Markus Artz
- Guillermo Palao Moreno
- Paul Matthews
- Patrick Wautelet
13:15 Lunch and end of the conference