The Doctrine of Renvoi is a legal doctrine which applies when a court is faced with a conflict of law and must consider the law of another state, referred to as private international law ("PIL" rules. This can apply when considering foreign issues arising in succession planning and in administering estates.
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The word “Renvoi” comes from the French “send back” or “return unopened”. The “Doctrine of Renvoi” is the process by which the court adopts the rules of a foreign jurisdiction with respect to any conflict of law that arises. The idea behind the doctrine is that it prevents forum shopping and the same law is applied to achieve the same outcome regardless of where the case is actually dealt with. The system of Renvoi attempts to achieve that end.

Single Renvoi
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Countries such as Spain, Italy, and Luxembourg operate a “Single Renvoi” system. This system refers to another jurisdiction’s choice of law rules. Where the matter arises in a jurisdiction such as Spain, Italy or Luxembourg (A), those jurisdictions will consider whether their own domestic law is the applicable law or if the applicable law is that of another jurisdiction (B). Where B’s rules might return the issue to A, (the original forum court), the court will accept the first remission and apply its own domestic laws.
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