European inheritance rules - FT.com The ability of the law to complicate the simplest of matters knows few bounds - and extends even beyond the grave. Investors, who build up assets in different European countries and want to plan ahead, understand this only too well. Legal systems in some countries, such as England, allow individuals to choose who inherits their estates (and define these as property at the date of death). But in others, they give family members an inalienable "forced heirship" claim (and include gifts made by the deceased during his or her life). So a British citizen, say, seeking to leave a French house and bank account to his wife, but ignoring his children, could have a big problem. Such a disposal would be permitted under English rules, but not under French ones. And in practice, neither is likely to triumph completely: the house will probably be governed by French rules and the bank account, by English ones. This mess is not just an issue for the super-rich. Almost 450,000 inheritances annually in Europe, or one-tenth of the total, have a cross-border element. Assets involved top €120bn. So, in principle, new rules passed in the European Parliament this week, look rather good. Under these, individuals can choose to have inheritance governed by their home country's laws. Absent any option, the jurisdiction of the country where they last lived will apply. But is life - or death - ever that simple? While this new regime will work for most Europeans, the UK, Ireland and Denmark are cold shouldering it. The UK's big worry is that this could start to undermine the legal certainty of gifts made while an individual is still alive - including to charities. The irony, though, is obvious. British citizens living in continental Europe can safely choose to apply English law to their wills; those resident in the UK (British or not) but with property elsewhere, still face a legal quagmire.