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64Information for citation:
Putintseva, E. P. (2021) Property Rights of Spouses in Case of Cross-Border Inheritance. European and Asian Law Review. 4 (1), 61-68. DOI: 10.34076/27821668_2021_4_1_61.
UDC 341.9
BISAC LAW051000
DOI: 10.34076/27821668_2021_4_1_61
Research Article
PROPERTY RIGHTS OF SPOUSES IN CASE OF CROSS-BORDER INHERITANCE
EKATERINA P. PUTINTSEVA
Notary of the city of Nizhny Tagil and the Prigorodny district of the Sverdlovsk region, Russia ORCID ID: 0000-0003-3758-9667
This article analyzes the practical and doctrinal problems associated with the documentation and determination of the scope of rights belonging to the surviving spouse in the event of international inheritance. These relations are at the junction of inheritance and family law, which causes difficulties in determining the law regulating these relations. In preparing the article, general scientific and special legal methods were used. In order to ensure the logical structure of the narrative, groups of problematic issues are distinguished, on the correct solution of which the final determination of the scope of the rights belonging to the surviving spouse depends. It is demonstrated that the application of the law of different states to inheritance relations and to property relations of spouses may result in a violation of the balance of the rights of the spouse and other heirs. The article substantiates the need to plan inheritance, if it is expected to be tied to more than one legal order, conclusion is made that it is necessary to expand the discretion in the international inheritance plan by providing an opportunity to choose the applicable law, and analyzes the potential value of the inheritance contract for ordering complex legal relations.
Key words: cross-border inheritance, conflict of laws, inheritance planning, inheritance contract, spousal property regulations, choice of applicable law
Introduction
The right to inherit is guaranteed by Article 35 of the Constitution of the Russian Federation and is an integral part of the property right. The norms of inheritance law are aimed at ensuring the transfer of rights to the property of a deceased person to his relatives, taking into account his will, and in the absence of its expression family relations. As a result of the globalization process taking place all over the world, the possession of real estate by one individual in different states has already ceased to be surprising, marriages between citizens of different countries have also become quite commonplace, respectively, the number of inheritance cases complicated by a foreign element will only increase.
The change in the nature of inheritance relations, the complication of the very concept of property, the emergence of new intangible assets, including digital rights, inevitably results in the need to modernize inheritance law. According to the fair expression of P. V. Krasheninnikov (2019: 46), the development of inheritance law is necessary in line with the concept of discretion. It seems that this development should affect not only national, but also international private law.
Any legal case that goes beyond the borders of one state is complicated due to the need to determine the applicable law, qualify legal concepts, interpret and apply the norms of foreign law. Speaking about the
Copyright© 2021. The Authors. Published by Ural State Law University. This is an open access article distributed under the CC BY-NC 4.0. license http://creativecommons.org//license/by-nc/4.0/
property rights of spouses in cross-border inheritance, it must be borne in mind that this topic is a whole mass of problematic and controversial issues, as a result of which predicting the outcome of a particular legal case becomes an intractable task.
The doctrinal and practical problems associated with the registration of cross-border inheritance have undoubtedly caused and continue to cause civilized interest and are consecrated both in separate fundamental works (Boguslavsky, 2004: 440-459, Zasemkova, 2018: 200-206, Medvedev, 2015: 140-176) and in scientific articles (Trofimets, 2020: 43-47, Medvedev, 2016: 35-47).
Materials and methods
During the development of this topic, general scientific methods were used: cognition, analysis and synthesis. As special methods the following were used: comparative legal, formal legal and legal modeling methods.
Results
Analyzing the procedure for determining the rights of spouses in an inheritance case complicated by a foreign element, several groups of issues can be distinguished, the final result of which depends on the correct solution.
Competence
One of the first problems is the determination of a competent person who has the right to accept a specific inheritance case for his proceedings. Of course, defining the starting point from which the situation begins to be considered is a key value to making the final decision.
The law enforcement officer justifies his competence on the basis of an international treaty, and in its absence - on the basis of the internal norms of his law. Due to the limited scope of this article, it is impossible to disclose in detail the content of not only all, but even the main treaties that touched upon issues of inheritance law. One should only pay attention to the fact that most of the international treaties in which Russia participated are of a bilateral nature. Some treaties address only the applicable law, but not competence. An example of an agreement in which the issue of competence is separately resolved, and separately - on applicable law, is the 'Convention on Legal Assistance and Legal Relations in Civil, Family and Criminal Matters', concluded in Minsk on January 22, 1993 (hereinafter referred to as Minsk Convention)1.
Determination of the applicable law
However, the main difficulty lies not in determining the competent person, but in the fact that the relationship associated with the participation of spouses in inheritance affects the area of both family and inheritance law. At the same time, family law provides for its own rules of conflict of laws, and inheritance law - its own.
So, on the basis of Article 1224 of the Civil Code of the Russian Federation (hereinafter referred to as the CC RF) the law applicable to inheritance relations is determined, and on the basis of Article 161 of the Family Code of the Russian Federation (hereinafter referred to as the IC RF) the law applicable to the property relations of spouses is defined. Many conventions and bilateral treaties are made on exactly the same principle. For example, in accordance with Article 27 of the Minsk Convention, individual and property legal relations of spouses are determined according to the legislation of the Contracting Party in whose territory they have joint residence. Rules of conflict applicable to inheritance issues are contained in Article 45 of this Convention, and differ depending on the type of inherited property. Thus, the situation is quite predictable when property relations between spouses will be regulated by one rule of law, and inheritance - by another.
Currently, there are the following main types of connecting factors when determining the order of inheritance:
1) Splitting the inheritance statute: the application of different rights to the inheritance of movable and immovable property:
The inheritance of immovable property is determined by the law of the location of the thing, and movable property - by the law of the last place of residence of the testator or his citizenship (for example,
1 Article 48 defines the competence in inheritance cases, Article 45 defines the law applicable to inheritance.
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in Russia - the law of last residence - for movable property, the law of the place of location of the property - for immovable one).
2) Uniform hereditary statute:
general statute - last place of residence (EU countries),
general statute -citizenship (Japan).
With regard to family relations, the following types of connecting factors are distinguished:
1) joint place of residence of the spouses (clause 1 of article 161 of the RF IC),
2) the first joint place of residence of the spouses (Art.26 of the EU Council Regulation 2016/1103 of June 24, 2016 on expanding cooperation in the sphere of jurisdiction, applicable law and the recognition and enforcement of decisions on the property regulations of spouses, hereinafter referred to as the EU Regulation on the property of the spouses),
3) the law of general citizenship (clause 2 of article 27 of the Minsk Convention),
4) the legislation of the country with which there is the closest relationship (Article 26 of the EU Regulation on the property of spouses).
At the same time, the specific scope of rights belonging to the surviving spouse in the framework of the inheritance case often depends on the legal regulation that applies to the property rights of the spouses. It must be borne in mind that spouses are not related to the testator by blood relationship, and therefore in the legislation of many countries they stand apart, and the scope of their rights depends on which line of heirs is called to inherit. In Russian law, on the contrary, in the absence of a marriage contract, the spouse not only receives half of the jointly acquired property, but also acts as an ordinary heir of the first stage.
Inheritance law, like family law, is quite conservative. The legal order of a number of countries has their own unique rules governing the position of spouses in the process of inheritance, giving them any special rights. If the spouse has a sufficiently strong position in the framework of family law, then the spouse's rights during inheritance may be limited, and vice versa. If, as a result of the application of rules of conflict of laws, the applicable law is determined differently to inheritance and family relations, then this balance may be violated.
Mobile conflict can add additional complexity to the case - a change in the time of the connecting factor in comparison with the day of the marriage. If the spouses moved from one country to another during the marriage, then the change of place of residence, from the point of view of the legislation of individual countries, may result in a change in the family legal statute.
Of course, any international problem requires an international approach to its solution, which implies the need to achieve interstate agreements. There are a sufficient number of treaties and conventions in the world concerning inheritance issues. At the same time, most international treaties, as a rule, do not contain substantive regulation, but only refer to the legislation of a particular country, on the basis of which a specific legal relationship will be considered.
Of course, attempts to unify the substantive norms of inheritance law have already been made. One of the striking examples of the unification of norms of inheritance law is the Bustamante Code (Appendix to the Convention on Private International Law, which entered into force on November 25, 1928). Considering the need to overcome the national peculiarities of inheritance in order to ensure the free migration of citizens of the European Union, the European Parliament on July 4, 2012 adopted Regulation No. 650/2012 'On Jurisdiction, Applicable Law, Recognition and Enforcement of Decisions, Adoption and Execution of Notarial Acts on Inheritance Matters, and on the Creation of a European Certificate of Inheritance' (hereinafter referred to as the EU Regulation on Succession Law).
At the same time, given that the above normative acts are of a local nature, they do not remove all the problems arising in the framework of cross-border inheritance.
Differences in national law
Many of the difficulties associated with determining the rights of the surviving spouse are primarily due to the presence of strong national traits in the family and inheritance law of many countries: some countries allow polygamy, and some - same-sex marriages. For example, in Germany, persons of the same sex can register a partnership, which, in terms of its legal, including inheritance law, consequences are similar to marriage (§§ 2.3 of the German Law on Registered Partnerships).
In the event of cross-border inheritance affecting the legal order of two CIS countries, as a rule, there are no special difficulties, since the general principles of the law of these states coincide. At the same time, practice shows that the most in demand is real estate in the warm countries of Europe, which sooner or
later will lead to an increase in inheritance cases related to the law of European states. And if we compare the substantive family and inheritance law of Europe and the CIS, the differences become much more significant.
First of all, the legislation comes from different regimes of matrimonial property. The following main regimes of property of spouses are distinguished in the world:
1. separate ownership regime (for example, Great Britain),
2. regime of joint ownership (for example, Russia),
3. regime of 'deferred community' (Zugewinngemeinschaft) - Germany.
The circle of heirs, the presence of the right to a compulsory share also has significant differences in the substantive law of individual countries.
Relationship to the mandatory share:
1. the spouse is entitled to a compulsory share (Germany),
2. the spouse has the right to a compulsory share if he is disabled (Russia),
3. there is no right to a compulsory share at all (common law countries).
Tax issues
From the point of view of organizing the effective transfer of property rights from the testator to the heir, it is necessary to take into account not only the norms of civil and family law, but also the costs incurred by the heir as a result of such an acquisition. Taxation of inheritance property is only indirectly related to notarial actions, however, in practice, it plays a key role in planning international inheritance. As rightly noted by D. V. Vinnitskiy (2017: 31), 'the initial desire of specialists in the sphere of private international law to consider tax problems, namely double taxation of cross-border inheritances and other transfers of property in the context of the system of science of private international law, is quite understandable'.
In Russia, there is no inheritance tax, in Germany it can reach 40% and depends on the value of the inherited property, as well as on the degree of relationship with the testator. Spain does not have uniform inheritance tax legislation, and there are significant regional differences among the Autonomous Communities. In the UK, inheritance tax can also reach 40%, but some categories of heirs are exempt from tax. It is also necessary to take into account that, in addition to taxes, the amount of fees for registration of rights to property, the presence of expensive intermediaries in the process of transferring inherited property, etc., also affects the value of inheritance.
Discussion
As an illustration of the difficulties that can be encountered in the framework of an inheritance case, we suggest discussing a hypothetical situation. Suppose that spouses, former citizens of Russia, moved to Germany for permanent residence, received German citizenship, bought a land plot with a house there, and now they have savings in a German bank. In Russia, they still have an apartment acquired during marriage and registered in the name of her husband. There are no orders in the event of death, as well as a marriage contract. The couple has two children: a son and a daughter.
It is obvious that the inheritance case will be opened both in Germany and in Russia. There is no legal aid agreement between Germany and Russia. The consular agreement between the Union of Soviet Socialist Republics and the Federal Republic of Germany (Bonn, April 25, 1958) provides for the consul's rights to participate in measures to protect inherited property, and also contains one single rule of conflict of laws: the legislation of the country where the property is located applies to immovable inherited property (Clause 3, Article 28).
From the point of view of Russian law, the rules of inheritance of real estate located on the territory of Russia are always determined on the basis of Russian law (paragraph 2, paragraph 1 of article 1224 of the Civil Code of the Russian Federation), and property rights of spouses are based on the law of the country where the spouses have a joint place of residence (clause 1 of article 161 of the RF IC). That is, in relation to the analyzed situation, the circle of heirs for an apartment will be determined on the basis of Russian law, and rights of the surviving spouse - on the basis of German law.
The German court in determining the applicable law of inheritance will be guided primarily by EU norms. In accordance with Article 21 of the EU Regulation on inheritance law21 as a general rule, the law
2 The regulation applies to inheritance relations complicated by a foreign element, if the death of the testator occurred after 2015.
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of last place of residence of the testator applies to the regulation of inheritance relations, regardless of the type of inheritance.
In accordance with Article 26 of the EU Regulation on the property of spouses31 if the spouses have not determined the applicable law themselves, property rights of the spouses are governed by the law of the state:
a) in which the spouses after marriage have their first joint usual residence, or otherwise
b) the citizenship of which both spouses had at the time of marriage, or otherwise
c) with which the spouses are most closely related, taking into account all the circumstances at the time of marriage.
Based on the analysis of these norms, in the given example, the German enforcer will most likely apply Russian law to the regulation of spouses' property rights.
It turns out to be a rather paradoxical situation: the German enforcer will be guided by the norms of Russian family law, and the Russian, on the contrary, by the norms of German law, and this, given the fact that the application of foreign legislation is always a deliberate difficulty.
The legal regime of property of spouses in Germany is the regime of community of property (deferred community), which has no analogues in Russian law. Under the communal regime, the property acquired by the spouses during the marriage does not become their joint property (paragraph 2 of § 1363 of the German Civil Code, hereinafter referred to as the GCC). In the event of the termination of the marriage, the property acquired during the marriage is subject to division according to certain rules. To carry out the division, the value of the property of each of the spouses at the time of marriage (original property) and the value of the property of each of the spouses at the time of the end of the marriage (final property). By subtracting the value of the initial property from the value of the final property, it is possible to determine the property benefit received by each of the spouses during the marriage (Gongalo, Mikhalev & Petrov, 2015: 189). The one of the spouses who received less benefit during the marriage has the right to demand from the second spouse to pay him half of the cost of the difference between the property benefits of the spouses (§ 1378 GCC).
In accordance with § 1931 GCC, as a general rule, the surviving spouse of the testator is called as heir by law: along with relatives of the first stage - to one fourth of the inheritance.
In the event of the death of one of the spouses, instead of determining the amount of property benefits received by each spouse during the marriage, the German legislator granted the surviving spouse the right to receive one fourth of the estate in addition to the inheritance share determined on the basis of § 1931 GCC (paragraph 1 § 1371 GCC). If the testator has circumvented his/her spouse in the will, the latter may demand equalization of the property benefits received during the marriage in accordance with the general rules provided for in §§ 1373-1383, § 1390 GCC, as well as the provision of a compulsory share (paragraph 2 of § 2303 GCC). The spouse has similar rights in the case of a rejection of the inheritance.
Returning to the analyzed example, we can come to the conclusion that wife (or husband), son and daughter in equal shares have the right to inheritance (Article 1142 of the Civil Code of the Russian Federation). If you are guided by Article 161 of the Family Code of the Russian Federation, then the property regime of spouses should be determined on the basis of German law. Since spouses did not have a marriage contract, the regime of deferred community should be considered as such a regime, from which the conclusion logically follows that there is no marital share in the specified apartment.
At the same time, if Russian family law were applied to these relations, then the surviving spouse, in addition to 1/3 of the share acquired as a heir, would receive an additional 1/2 share in the apartment as a share in joint property. And if the family and inheritance law of Germany were fully applied to these legal relations, then the spouse, instead of equalizing property benefits, would be given the right to an additional share in the inheritance (j + j). Obviously, there is a violation of the balance of family and inheritance law.
Considering the difficulties described, there is a reasonable desire to accept the return link, since Article 26 of the EU Regulation on spousal property refers exactly to Russian law. But the Family Code of the Russian Federation does not contain any rules on return referral at all, limiting itself only to general rules on establishing the content of foreign law and on a public policy clause. In the legal literature, one can
3 The regulation applies to the regulation of family relations complicated by a foreign element, if the marriage was concluded after 2018.
find justified doubts about the possibility of applying a reverse reference to the legal status of the spouses' property (Tolstykh, 2002: 187; Marysheva, 2007: 13).
Based on the above, the importance of prior planning of inheritance becomes obvious. A certain clarity in the documentation of future inheritance rights can be made by drawing up testaments in the event of death and a marriage contract, since the indicated documents will make it possible to establish the true will of the spouses, and in some cases - to choose the applicable law.
The possibility of choosing and changing the applicable law (with restrictions) is provided, for example, by the EU Inheritance Regulation (Article 22) and the EU Regulations on Spousal Property (Article 22).
In accordance with paragraph 2 of Article 161 of the Family Code of the Russian Federation, when concluding a marriage contract, spouses who do not have common citizenship or joint residence can choose the legislation to be applied to determine their rights and obligations under the marriage contract. In accordance the Russian legislation it is not allowed to choose applicable law in a will under any circumstances. Accordingly, if both spouses have Russian citizenship and live together, then they cannot determine the applicable law either within the framework of family or inheritance relations.
The content of testaments also has to be approached with caution. At present, in the Russian legislation both the joint will of the spouses and the inheritance agreement have been already recognized, at the same time; the possibilities for determining the order of succession are still very different. So in Russian legislation long-term trust management of inherited property is impossible, initial and subsequent inheritance.
The inheritance contract has serious potential in the planning of inheritance. An inheritance contract, in which spouses participate, as well as persons who may be called to inherit from each of the spouses, may determine the procedure for the transfer of rights to the common property of spouses or the property of each of them in the event of the death of each of them, including the one that occurred simultaneously, to the surviving spouse or other persons, determine the property included in the hereditary mass of each of the spouses, if this does not violate the rights of third parties (clause 5 of article 1140.1 of the Civil Code of the Russian Federation). Thus, an inheritance contract can combine elements of family and inheritance law.
In the legal literature you can find various examples of the use of these legislative possibilities for organizing the optimal transfer of rights to inherited property, taking into account the will of both spouses. Unfortunately, an obstacle to the implementation of these ideas is the rather weak elaboration of the legal structure of the inheritance contract in the Civil Code of the Russian Federation. The legislator put the freedom of will at the head, allowing almost unlimited unilateral cancellation of the inheritance contract, as a result of which the contractual nature of this legal phenomenon has been lost. Moreover, given the literal wording of paragraph 5 of Article 1140.1 of the Civil Code of the Russian Federation, the definition of property included in the estate should not affect the rights of third parties. However, almost any change in the property regime of spouses will entail a violation of the interests of the heirs under the law, who expected to receive inherited property, in connection with which there are concerns about the possible unreasonably wide application of this rule by the courts in case of disputes. Of course, the inheritance contract should not be used by spouses for the purpose of abuse of the right, for example, with the aim of avoiding obligations to creditors, but the protection of the rights of absolutely any third parties to the detriment of the spouses' right to determine their own property relations seems excessive.
Such legal researchers as E. Yu. Petrov drew attention to the insufficient elaboration of the rules on joint will and inheritance contract (Petrov, 2018: 457-482), A. L. Makovsky (Vitryansky, Golovina & Gongalo, 2019: 323). The latter wrote, 'that neither the nature of the joint will, as well as the inheritance contract, nor the place of these institutions in the system of Russian inheritance and civil law in general are not defined by the Law of July 19, 2018'. The question of the law applicable to relations under a joint will and inheritance contract also turned out to be unresolved. Paragraph 2 of Article 1224 of the Civil Code of the Russian Federation contains a rule of conflict of laws determining the law applicable to a person's ability to draw up and revoke a will, as well as the form of such a will or an act of its cancellation. The application of these rules by analogy to an inheritance contract may not always be effective, since its legal nature is different. For example, the problem of the possibility of free disposal of the property specified in the inheritance agreement in the event of a change in the place of residence of the parties to the agreement
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remains unclear, since the legislation of different countries provides for completely different approaches to determining the binding force of an inheritance agreement.
Conclusion
The intensification of international relations, the complication of the composition and the increase in the value of hereditary property result in the complication of hereditary legal relations. Serious efforts are required not only on the part of civil science, but also on the part of state bodies in order to find ways to overcome the problems arising in the framework of international inheritance. Rules of conflict contained in Article 1224 of the Civil Code of the Russian Federation and Article 161 of the Family Code of the Russian Federation no longer meet the needs of modern society, do not take into account the relationship between inheritance and family legal relations, ignore the problem of applicable law to an inheritance contract and a joint will.
Prospects for the development of international inheritance law are seen, first of all, in strengthening discretion, providing spouses with the opportunity to determine their property relations independently. To achieve this goal, it seems advisable to expand the possibility of choosing the applicable law, including by providing this opportunity to the testator, when at the time of drawing up the will it is obvious that inheritance relations will affect more than one legal order. A conceptual study of the place of the inheritance contract in the system of civil law of Russia is required in order to establish its correlation with the marriage contract, as well as with other institutions of civil law, which ultimately will help to make the inheritance contract a reliable way of regulating complex family and inheritance relations.
References
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Information about the author:
Ekaterina P. Putintseva - Candidate of Juridical Sciences, Notary Public of the city of Nizhny Tagil and Prigorodny District of the Sverdlovsk Region (56 Goroshnikova Str., Nizhny Tagil, Sverdlovsk region, 622001, Russia, e-mail: e23p@rambler.ru).
© E. P. Putintseva, 2021
Date of Paper Receipt: May 9, 2021
Date of Paper Approval: June 28, 2021
Date of Paper Acceptance for Publishing: July 26, 2021
