01Applicable law
Which law decides who gets what
- Under Russia rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.
Succession: Russia → France
What happens to the estate
Case complexity: medium. The testator resides in Russia, the heir resides in France.
Testator
Citizen of Russia
Resident of Russia — the centre of life.
Heir
Resident of France
The estate stays in one jurisdiction — a simpler process.
0%
inheritance tax in Russia — but assets are taxed where they sit.
02Forced heirship
Who the law forces you to include
- Russia: Forced share: minor or incapacitated children and incapacitated spouse/parents receive at least ½ of their intestate share.
03Tax
Where tax arises
- Russia: No inheritance tax in Russia (abolished in 2006).
04Recognition
How it is recognised and processed
- Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).
05What to set up
What to set up in advance
Key risk
Part of the estate is reserved by Russia law for close relatives — it cannot be freely reallocated by will.
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This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.
Contact information
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