Comparative analysis of legal systems of inheritance relations in international private law

This article analyzes the existing legal systems in private international law (hereinafter referred to as the MCHP). It is determined that when regulating hereditary legal relations, contradictions often arise between the domestic legislations of different countries. Examples of countries using universal and separate legal systems are given. The main features of legal systems that determine their specifics are presented. It is noted that the main method of regulating hereditary legal relations is the conflict-of-laws method, which is applied on the basis of national conflict-of-laws norms of states. In addition, the main problems related to the definition of categories of movable and immovable property in various countries and ways to solve them are considered. The conclusion is made about the importance of the location of real estate in inheritance.