Unlike the English legal system, which is based on Common law, French Law is based upon a civil codified law system (the “Code civil”), although case law (“jurisprudence”) also plays an important part.
Many differences exist between these two legal systems. For instance the principle of trust plays an important part in the English conveyancing process where trustees hold the legal estate in a joint tenancy on behalf of the beneficiaries. In contrast, trusts are hardly recognised in France and a property purchase will be in most cases structured in “indivision” (equivalent to a tenancy in common) unless the buyers have requested an alternative structure. Furthermore, there is no concept in France of an executor who has been entrusted under an English Will to distribute the assets of the estate and pay the debts. Instead, the assets of the French estate devolve on the heirs or beneficiaries who are responsible for the payment of the debts and taxes.
With over 10 years’ experience in dealing with French legal services, our bilingual team will give you plain English advice and ensure that your French affairs are dealt quickly and cost efficiently.
Our French legal services include:
Francophile Legal Consulting Ltd
25 North Row, Mayfair, London, W1K 6DJ