Certificato successorio europeo: alcune osservazioni critiche.

The paper focuses on the European Certificate of Succession, established by EU Regulation No. 650/2012: a number of issues linked to its application are examined. According to Article 63 of the Regulation, in cross-border inheritances the Certificate may essentially be used to demonstrate the status and the rights of each heir in more than one Member State. Nevertheless, given that this instrument appears to be modelled after the German Erbschein, its usage could lead to some differences in treatment between (on the one hand) an heir whose situation is entirely regulated by Italian law and (on the other hand) an heir subject to both Italian and German – or even French – law.