Using powers of attorney across borders: planning for incapacity between Scotland and France

When life and assets span more than one jurisdiction, careful planning is essential to ensure that personal wishes are respected and legal authority is recognised.

Our speakers, Xaviera Favrie of KL Notaires in Paris, and Jessica Flowerdew, partner at Brodies LLP examined:

• the key differences between powers of attorney and other measures to protect vulnerable adults in Scotland and in France (including guardianships and other arrangements);
• the extent to which Scottish powers of attorney and guardianship orders are recognised in France – and vice versa; and
• practical strategies for individuals and families with connections to both jurisdictions to ensure that plans for incapacity are effective and respected.