Cologne Court of Appeal: Application of English law can violate the German Public Policy

Cologne Court of Appeal: Application of English law can violate the German Public Policy

The Cologne Court of Appeal has held in its judgment of April 22, 2021, file no. 24 U 77/20, that English law regarding the forced share is not applicable due to a violation of German public policy if a UK national (with the closest connection to England) with habitual residence in Germany elects British law to govern "succession as a whole" pursuant to Art. 22 of the European Succession Regulation. 

 

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