Grensoverschrijdende erfopvolging. Behoud van nationale conflictenrechtelijke waarden in de nieuwe Europese regelgeving

The present research is primarily concerned with the conflict rules of the Regulation on succession published in the Official Journal of the European Union on July 17, 2012. The Regulation stipulates the rules of private international law in matters of succession. This study deals with fundamental principles of the European conflict rules on succession and with the question whether these principles already exist in member states’ current national systems of conflict rules. In this way it will be possible to understand the measure in which the national conflict rules of member states will continue to be preserved when the Regulation on succession enters into force. A comparative study of the Dutch, French and Swedish national systems is performed.The Regulation shall apply to the succession of persons who die on or after 17 August 2015.