The European framework
Regulation (EU) 650/2012 applies to succession to the estates of people dying on or after 17 August 2015, subject to its scope and transitional provisions. Cyprus participates. Ireland and Denmark do not; the United Kingdom did not participate. An estate connecting a participating state and another country still requires a coordinated analysis.
Habitual residence and choice of law
Article 21 generally points to the law of the state of the deceased’s habitual residence at death, with an exception for a manifestly closer connection. Under Article 22, a person may choose the law of a state whose nationality they possess at the time of the choice or at death. This is not a general right to select any convenient legal system.
One estate, several practical processes
The Regulation aims at a law governing succession as a whole, but excludes matters such as tax and certain company and property-registration issues. A choice-of-law clause does not remove every local formality. Foreign wills should be reviewed together to avoid unintended revocation or inconsistent provisions.
The European Certificate of Succession
The Regulation creates an optional certificate for use by heirs, legatees with direct rights, executors and administrators who need to demonstrate their status or powers in another participating Member State. It does not replace every national document. Whether it is useful depends on the assets and countries concerned.
Information to bring
Prepare a timeline of residence, nationalities, all wills, the location of assets, marriage or partnership information and any existing foreign grants. Explain which advisers are already involved so the Cyprus work can be coordinated with the overseas estate.