A will must be formally valid and substantively effective in each country where your assets or heirs are located.
- Form: France applies the Hague Convention of 5 October 1961, accepting wills made under the law of the place of execution, the testator’s nationality, domicile or habitual residence, or, for immovables, their location. The international will under the Washington Convention of 26 October 1973 also provides a form recognized in States adopting it: it is signed before a notary and two witnesses.
- Substance: the law governing your succession, that of your last habitual residence or your nationality if chosen, determines what you may leave, the share reserved for your children and your spouse’s rights.
- Coordination: if you make several wills, for example one per country, each must identify the assets it covers and avoid revoking the others. Their clauses must remain consistent with one another and with your choice of law.
In France, your notary enters the will in the central register of testamentary dispositions so it can be found on death.