Variations in property laws can cause problems when it comes to distributing an estate in more than one jurisdiction. Brendan Harper, technical services manager at Friends Provident International, explains
It is becoming increasingly com-mon for individuals to own property in one or more countries other than their country of residence. Whether it is an investment, a dream holiday home or retirement property, it is important to understand succession laws vary greatly from country to country. The laws of certain countries vary so greatly from others that sometimes the distribution of an estate that involves one or more jurisdictions can result in a direct conflict of laws. When this happens, generally international law will dictate that real estate and land will be distributed in accordance wit...
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