French Inheritance and UK Debt liability

unholyangel

unforeseen wrote: »

Which appears to be what the OP has done. They have taken a copy of the will to the not sure who has done what was needed. The French assets have then been dealt with under French Inheritance laws as they do not fall within UK law because we didn't sign up to the cross border agreement. For that reason they cannot be dealt with under UK probate law.

We didn't sign up to it, but france did.

https://europa.eu/youreurope/citizens/family/inheritances/planning-inheritance/index_en.htm

EU rules on inheritance do not apply in Denmark, Ireland and the UK. If your heirs decide to settle your inheritance with an authority in these countries, your choice of law may not be taken into account. However, Danish, Irish and British citizens can benefit from these EU rules and choose the law of their nationality for their inheritance if this is handled in an EU country other than Denmark, Ireland and the UK.

That page also supports my point of it being all one estate and that the location of the assets dont determine what law applies to the succession (although it may affect what taxes are due or how assets need to be handled).