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Dual nationality queries - should I choose UK or French law?

Every other day, we share a reader question from our Help Guide, Inheritance Law and Wills in France. Today's question: I have dual nationality so will French law be imposed on my estate?


I recently was granted French nationality as I applied partly with a view to protecting my rights after Brexit, and so now have dual British-French nationality. I live in France. Can I still opt for British law via the regulation or will France insist that French law much apply to my estate now?

Applying for French nationality: What it's like


Prior to the regulation coming in there were some concerns about this as in most situations where nationality is concerned France sees a person with dual French and another nationality as simply being French. However this concern has proved to be unfounded.

In fact this situation is specifically provided for by article 22 of the regulation, which states: “A person possessing multiple nationalities may choose the law of any of the states whose nationality he / she possesses at the time of making the choice or at the time of death”.

This rule has been respected in France and so in the vast majority of cases there should be no problem with this. Lawyers think it could only be subject to a (theoretical) legal challenge (eg. by one of your children who did not receive the share provided for in French law) in exceptional circumstances and we are not aware of any cases where this has occurred.

Find out all the information you need to create a will in France and more with our Inheritance Law and Wills in France 2020 Help Guide

This 64-page Help Guide by The Connexion details all the information you need to know about inheritance law and wills in France. It looks at how to create a British will in France, explains succession laws, procedures on a death, creating a will as a couple, leaving funds to family and pets, and so much more. Click here to find out more.

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