Many people have a holiday home or holiday flat abroad. In the event of inheritance, the question then arises as to how this property located abroad is rewritten.
Almost all EU member states record the properties located on their territory in a register. However, each country has its own regulations regarding the organisation of the register, the information it contains and the conditions under which entries are made.
In order for the register to make a transfer of ownership in the event of inheritance, the succession must be proven. If the property is located in the country in which the deceased had their last habitual residence, the succession is usually proven to the register by means of a national certificate of inheritance.
However, if the deceased had their last habitual residence in another country, a European Certificate of Succession (ECC) must be applied for there, which can then be used to prove the succession to the register of the country in which the property is located.
However, most registers in other EU countries are not satisfied with the mere submission of a European Certificate of Succession issued by another member state. Some registers require the submission of further documents, such as the death certificate, a certified translation of the ENZ or an extract from the register of wills (Latvia, Greece, Estonia). Some registers require the property to be named in the European Certificate of Succession (Romania, Croatia, Lithuania). For this reason, the requirements of the register abroad must be taken into account when applying for the European Certificate of Succession. Careful preparation is required here to ensure that the transfer from the register is actually carried out.