L. Zielonka & Partners at the Annual Conference on European Succession Law in Barcelona

On 21-22 May 2026, a partner of L. Zielonka & Wspolnicy Kancelaria Prawna i Podatkowa sp.k. participated in the Annual Conference on European Succession Law, organised by the Academy of European Law in Barcelona and online.

The conference brought together leading European experts in succession law, including academics, judges, notaries, lawyers and representatives of EU institutions. The event focused on the most important practical issues arising in cross-border inheritance matters within the European Union.

For our law firm, participation in this conference was particularly valuable because we regularly advise foreign clients in inheritance cases involving assets, heirs or family members located in Poland.

Cross-border inheritance cases require more than knowledge of local law

Inheritance cases increasingly involve several jurisdictions at the same time. A person may live in one country, hold citizenship of another, leave assets in Poland, and have heirs living in different parts of Europe or outside the EU.

In such cases, it is crucial to determine:

• which court has jurisdiction;
• which law applies to the succession;
• whether Polish courts or authorities may deal with the estate;
• how foreign documents should be recognised;
• whether a European Certificate of Succession may be used;
• how assets located in different countries can be identified and transferred.

These were among the key issues discussed during the conference.

Recent CJEU case law and the EU Succession Regulation

A major part of the conference was devoted to recent case law of the Court of Justice of the European Union concerning the EU Succession Regulation.

This is highly relevant in practice because many inheritance disputes depend on the correct interpretation of concepts such as habitual residence, applicable law, jurisdiction, and choice of law. These issues are often decisive in cross-border cases involving Polish real estate, foreign heirs, or estates administered in more than one country.

For clients, this means that a proper legal assessment at the beginning of the case can prevent costly mistakes later in the proceedings.

European Certificate of Succession and identification of assets

The conference also addressed the European Certificate of Succession, including its content, practical use, and challenges related to the identification of estate assets.

This is particularly important for heirs who need to prove their rights in another EU Member State. In practice, the European Certificate of Succession may help heirs deal with banks, land registers, notaries or public authorities in different countries.

At the same time, the conference highlighted that the certificate must be used carefully, especially where there are disputes concerning the scope of the estate, the identity of heirs, or assets located in several jurisdictions.

Estate planning, trusts, foundations and company structures

Another important topic was estate planning, including the use of trusts, foundations and other asset-holding structures.

This part of the conference was especially relevant for cases where inheritance does not concern only private assets, but also company shares, family businesses, foundations or assets transferred before death.

In practice, such cases often require a combined analysis of inheritance law, company law, tax issues and asset protection mechanisms. This is particularly important where heirs suspect that assets were transferred to companies or third parties before death.

The role of notaries in international succession matters

The conference also discussed the functions and duties of notaries in international inheritance cases.

This is a key practical issue, as many succession matters in Europe involve cooperation between courts, notaries and public registers. Depending on the case, notarial procedures may be faster and more efficient than court proceedings, but they are not always available, especially where there is a dispute between heirs or uncertainty about the estate.

For foreign clients dealing with Polish inheritance matters, understanding the difference between court and notarial succession procedures is essential.

Digitalisation and the future of succession proceedings

The final part of the conference focused on digitalisation and the future development of European succession law.

Digital tools, electronic registers and cross-border exchange of information are becoming increasingly important in inheritance matters. However, digitalisation also creates new challenges, particularly in relation to electronic documents, access to registers, digital assets and communication between authorities in different countries.

For clients, this means that inheritance proceedings are gradually becoming more international and more document-driven, requiring careful coordination between jurisdictions.

Why this matters for our clients

Participation in the Annual Conference on European Succession Law strengthens our firm’s ability to advise clients in complex cross-border inheritance matters.

At L. Zielonka & Partners, we assist clients with matters involving, among others:

• confirmation of inheritance rights in Poland;
• Polish real estate inherited by foreign heirs;
• European Certificates of Succession;
• inheritance disputes between family members living in different countries;
• recognition and use of foreign documents in Poland;
• tracing assets and verifying Polish land and mortgage registers;
• inheritance cases involving companies, shares and business assets;
• cooperation with foreign lawyers, notaries and courts.

Cross-border inheritance cases require not only knowledge of Polish law, but also an understanding of European private international law and the practical approach of courts and authorities in different jurisdictions.

By participating in international legal conferences of this kind, our firm continues to develop the knowledge and practical tools necessary to support foreign clients with Polish inheritance matters effectively and strategically.