Features of Inheritance in Private International Law

Abstract. The article discusses the issues of inheritance law in the context of private international law. Special attention is paid to conflicting norms and problems arising in the regulation of inheritance relations with the involvement of an international element, analysis of legal systems of different countries. Inheritance in international private law has an important practical significance, since in view of the migration processes and the growth of the pace of acquisition of real estate abroad, the urgency of the need to regulate inheritance relations complicated by a foreign element is beyond doubt. Regulation of inheritance relations in international private law is carried out in several ways: application of the conflict of laws rule and the rule of national material law to which it refers; use of norms contained in international treaties. The issue of legal regulation of inheritance legal relations complicated by a foreign element is solved using the conflict-of-law method of regulation, which determines the law of which state should be applied to regulate certain relations. Harmonization of inheritance legislation of Ukraine in the field of international private law and its convergence with the legislation of the European Union requires the solution of a number of issues, such as: clarifying the definition of the testator's last place of residence; establishing the order of succession of heirs according to the law depending on the degree of family ties; peculiarities of inheritance of movable and immovable property; removal from the right to inheritance; determination of the legal nature of the will of the spouses; inheritance by children born with the help of assisted reproductive technologies and others. Today, a significant number of people become participants in hereditary relations. This article analyzes aspects of inheritance in private international law. These aspects are considered as a key mechanism for achieving a certain consistency between national legal systems, reducing differences between them based on generally recognized legal principles and advanced concepts of legal culture. Keywords: inheritance; heirs; testators; conflicts of law; foreign element; inheritance law.