Andreas Giannakopoulos writes on choice of law under the EU Succession Regulation
22nd Jan 2024
Andreas Giannakopoulos has written a case note for Private Client Business on the CJEU’s recent decision in OP v Notariusz Justyna Gawlica (C-21/22). This case raised issues about the ability of non-EU nationals to choose the law of their nationality to govern their succession under article 22 of Regulation 650/2012 (Succession Regulation) and examined the relationship between the Regulation and international conventions. The note discusses the scope of choice of law under the Succession Regulation in light of that decision and considers the position post-Brexit of UK testators resident in the EU.
The case note is available here and was first published in P.C.B. 2024, 1.