European UnionI inherited a house in multiple EU countries. Can one court handle everything?
No — inheritance cases involving assets in multiple EU countries are generally handled by courts in the deceased’s last habitual residence, but national courts retain jurisdiction over immovable property located in their territory.
What the Law Says
EU Regulation (EU) No 650/2012 — the Succession Regulation — establishes uniform rules on jurisdiction, applicable law, and recognition of decisions in cross-border successions within the EU.
The Regulation applies to all EU Member States except Denmark and Ireland (which opted out). It aims to simplify cross-border inheritance by designating a single court and a single governing law for the entire estate — with one major exception.
Under the general rule, the court of the Member State where the deceased had their 'habitual residence' at the time of death has jurisdiction over the whole succession — including movable and immovable assets worldwide.
However, Article 4 explicitly preserves national jurisdiction over immovable property: 'Courts of the Member State in which the immovable property is situated shall have exclusive jurisdiction in matters relating to rights in rem in immovable property.' This means that if you inherited houses in France, Germany, and Italy, each country’s courts retain authority over the house located within its borders.
The Regulation also allows individuals to choose the law of their nationality to govern their succession (Article 22), but this choice does not affect jurisdiction — only the substantive law applied.
Statutory TextThe courts of the Member State in which the deceased had his/her habitual residence at the time of death shall have jurisdiction to rule on the succession as a whole.
— Regulation (EU) No 650/2012, Art. 4 — Jurisdiction
Statutory TextCourts of the Member State in which the immovable property is situated shall have exclusive jurisdiction in matters relating to rights in rem in immovable property.
— Regulation (EU) No 650/2012, Art. 4 — Jurisdiction
What Courts Have Said
EU courts have clarified how Article 4’s ‘exclusive jurisdiction’ for immovables interacts with the Regulation’s goal of a single forum.
The CJEU confirmed that national courts retain exclusive jurisdiction over immovable property located in their territory — even when the deceased was habitually resident elsewhere — and that this exception cannot be overridden by party agreement or choice of law.
The Court reaffirmed that Article 4 creates a mandatory, non-derogable rule: jurisdiction over land is always tied to location, limiting the reach of the ‘single court’ principle.
What to Do
Identify the deceased’s habitual residence at death — this determines the main succession court and applicable law.
List all immovable assets (e.g., houses) and their physical locations — each triggers separate national court jurisdiction.
File for a European Certificate of Succession (ECS) in the main jurisdiction; it’s recognised across EU states but does not override local property registration requirements.
Engage local legal counsel in each country where immovable property is located to handle title transfer, taxes, and court procedures.
Act within deadlines: appeals against succession decisions must generally be filed within 3 months in most Member States applying the Regulation.
Sources
Not legal advice. This article is general information based on publicly available sources, written for educational purposes. Laws change and individual situations vary. Consult a licensed attorney in your jurisdiction before acting on anything you read here. Last reviewed: 2026-06-08.