La sucesión mortis causa de ciudadanos británicos en España

Abstract

Abstract: English succession system is founded on different principles to the Spanish one. The respective substantive and private international law rules in this field have no similitude. Consequently, in the event of death of English citizens with residence in Spain some complex problems arise throughout the whole succession process, as we will have the opportunity to study all over this paper. Difficulties grow if the deceased owns properties located in England and in Spain. While the United Kingdom will not take part into the new European successions regime, Spanish authorities will apply its rules in our territory in order to determine the applicable law to the succession of English citizens deceased with habitual residence in Spain. Key words: International successions, European succession system, applicable law to the succession, professio juris, English law, administration of estates.