Important: For general educational information only. This is not legal, tax or financial advice, and reading it does not create a professional-client relationship. Laws and procedures vary by jurisdiction and can change. Consult a qualified professional in each place relevant to you and your assets before making decisions.
Map places separately from people
Where you live, your nationality, the location of a home and the location of an account can all be different. Write these down separately. Do not assume that a will signed in one place automatically settles every question in another place.
EU guidance on cross-border succession describes rules about the authority that handles an inheritance and the law it may apply. It also explains that some matters remain under national rules. That is a reason to ask questions, not a shortcut to deciding your own case.
Questions to bring to an adviser
- Where was your main residence, and might that change?
- Which countries contain property or other assets?
- Have you signed more than one will or made a choice-of-law declaration?
Ask how plans interact
If documents exist in different countries, ask qualified advisers whether one could affect another and how local signing or recognition rules work. Ask separately about estate administration, inheritance rights and tax. Those are related questions, but they are not identical.
EU cross-border succession guidance has a particular scope. It should not be treated as a universal rule for the UK, Singapore, Thailand, the Philippines or other places outside its framework. Even within Europe, checking the participating jurisdiction and current official guidance matters.
Questions to bring to an adviser
- Would a new will change an older one?
- Who could administer assets in each place?
- Which official records or translations would family members need?
Give your family a reliable starting point
Keep a secure index of assets, advisers and the location of original documents. The index can help family members contact the right institution or professional without making assumptions about their legal rights.
If you are considering a move or buying abroad, revisit the index first. A local lawyer or notary can explain the current rules that apply to your specific residence, nationality, family and assets.
Official starting points
Check these sources for updates; their guidance may have changed since our last source check.
This guide cannot determine which rules apply to you. Speak with a qualified professional in each jurisdiction relevant to your family and assets.