INHERITANCE STATUTE: A COMPARATIVE ANALYSIS OF THE LEGISLATION OF DIFFERENT STATES

Abstract

In the modern period, as a result of the comprehensive development taking place in the international arena, there has been an increase in the number of hereditary relations of an international nature. Regulation of basic international hereditary relations deemed to be one of the urgent problems of our time. The reason for this problem is that the substantive rights of States in this area differ from each other. Studying the legislation of the world countries in the field of inheritance and conducting a comparative analysis, we observe significant differences, the absence of an international regulatory mechanism in this area or the presence of certain legal gaps. It is obvious that legislative acts in the field of regulation of these relations are different both in content and in form.

Keywords

• mandatory share
• statute of inheritance
• heirs
• inheritance by law
• inheritance by will