Private international law is applicable to all situations involving one or more foreign asepects, which is frequently the case in the Principality.
An international legal situation may involve conflicts of jurisdiction or laws.
Each country has its own conflict of laws system.
Monegasque private international law is more piecemeal and fragmentary than the French system, making its application more difficult.
Differences are apparent between the Monegasque and French rules of application.
This especially applies for a trans-national estate of a deceased person.
France and Monaco have adopted a system of “scission”, that is to say enacting separate inheritance law for the moveable property and the real property.
France, together with many other countries, designates the law of the location for the real property and the domicile of the deceased for the moveable property.
The Principality has also chosen to designate the law of the location for real property but favours national law for moveable property.
The PASTOR-BENSA Law Firm is at your service to provide you with all the necessary advice to optimise the legislation applicable to your personal situation and your international assets.