El Reglamento (UE) 650 de 2012 de sucesiones internacionales y el paradigma forum/ius. Una mirada a su proceso de creación y su desarrollo jurisprudencial

This research studies the unification process that the eu under-went to adopt res 650/2012, which becomes an example for other dipr exercises. We emphasize the forum/ius unification paradigm of the habitual residence of the deceased or the law of his nationality in the case of professio iuris. We conclude that the great achievement of an instrument of this nature comes from the recognition of the European Certificate of Succession (cse) in the 25 signatory countries. The application of the paradigm chosen for the determination of the forum/ius has not prevented conflicts of jurisdiction between the signatory states, but its resolution has been successfully addressed by the case law of the cjeu in the application of the default criterion of connection of the habitual residence with respect to the testator’s ability to determine the applicable law of his country of origin as a determinant of international judicial competence.