Harmonization
The Hague Convention of 1 August 1989 on the Law Applicable to Succession to the Estates of Deceased Persons, if it ever comes into force, would apply to: a) the form of dispositions of property upon death; b) capacity to dispose of property upon death; c) issues relating to matrimonial property; d) property rights, interests or assets created or transferred otherwise than by succession, such as in joint ownership with right of survival, pension plans, insurance contracts, or arrangements of a similar nature. It nominates as the lex causae for succession the law of habitual resident if that was also the deceased's nationality. If the deceased had been resident in a state for at least five years and no other state has a better claim, the law of residence applies. In all other cases, the personal law with the best claim applies. See also the "European Commission's Green Paper Consulting on Succession with an International Dimension" by David Hayton
Read more about this topic: Conflict Of Succession Laws