[학술논문] Cross-border Succession in Japan, Korea and China and Related Legal Issues
...connecting factor is more appropriate, the lex patriae or habitual residence. Under the reference of the EU regulation, it is also suggested that, in order for the unity principle not to be broken up by another element, a renvoi should be restricted, where the deceased made a choice of the governing law for succession such as the law of habitual residence, the law of nationality and the lex situs.