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Q&As
Where does the rule come from that immovable property is governed on a non-domiciled person's death in accordance with the laws of their country of domicile, not in accordance with English laws relating to succession and inheritance?
The question concerns English principles of Conflict of laws (or private international law (PIL)) in matters of Succession.
The historical development of the Rules of PIL is outside the scope of Lexis®PSL Private Client. However, we understand that the applicable law for determining questions relating to immovables, known as Lex situs in common law systems, originated in the Middle Ages and that it draws upon
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