HARMONIZACIJA NASLEDNOG PRAVA U EVROPSKOJ UNIJI
Harmonization of Inheritance Law in the European Union

Summary/Abstract: In this paper author primary analyzes the dilemmas and issues conected with the harmonization of inheritance law in the European Union. Author notes that in the academic environment and EU institutions is widely accepted view that hereditary rights can not be unified in the European Union because of its specifics related traditions, culture and customs. To that inheritance law should remain in the jurisdiction of national legislation. However, the evident fact that number of trans-national inheritance, from year to year, is constantly increasing in the EU the question of harmonization process is present in the area of specific rules of inheritance. Due to the efficient execution of hereditary rights of citizens of EU member states, it is suggested primarily harmonization of rules of private international law concerning the jurisdiction of inheritance, probate recognition and enforcement of decisions, the introduction of the European certificate of inheritance and the European register of wills. With these the main aim will be achieved and that is possibility of the citizens to plan and to organise their succession with a limited choise of the competent inheritance law in their last will. Harmonisation of the specific rules that are proposed in the area of inheritance law will be very useful for the citizens of the EU. That’s why, beyond the obstacles form UK it is desireble this idea to be realised for the other member states of EU, that belong to the europen-continental system of law.

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