The German view
From a German perspective, the Applicability of the law under the European Succession Regulation (EuErbVO). As we have already devoted a separate article to this issue, we will not go into it in detail here. If the deceased had their habitual residence in Canada at the time of their death, Canadian inheritance law applies. The testator can only prevent this by making a choice of law.
The Canadian view
From a Canadian perspective, the inheritance law of the state in which the deceased was domiciled at the time of death is applicable. However, it should be noted that Canada does not have a standardised inheritance law. Canada is a multi-jurisdictional state, meaning that it is not possible to speak in general terms of „Canadian inheritance law“. Rather, it must be examined specifically in which territory the deceased was domiciled. If you have any further questions, please contact your specialist inheritance lawyer in Düsseldorf and Krefeld, Dr Michael Gottschalk.