X is a German national, UK resident for tax purposes for over 20 years. During that time X has lived with his wife Y a UK national, at Greenacres in England, jointly owned as their only home. X has no immovable property in Germany, but on the death of his mother he expects to inherit a quarter of her German estate. X also has shares in the family business in Germany.
I understand that under the EU succession regulation 650/2012 it is not possible for X to choose the law of habitual residence (England/Wales) to cover succession, it would only be possible to choose his law of nationality. Therefore as I understand it, since UK either is or is about to become a third state, Germany as the state of nationality would have universal jurisdiction if X had any assets at all in Germany.
Q1: If X could show that he is now domiciled in England and Wales, would English succession law be applied to his movables and the lex situs (in this instance England/Wales) to Greenacres?
Q2:If X took dual citizenship, could he elect under the EU succession regulation for English succession law to apply to his worldwide estate?