International Wills: Making Your UK Will Valid Abroad

Moving abroad doesn’t mean your UK Will becomes irrelevant. Whether you’re a British expat with property or investments in the UK, or a foreign national with assets here, the law of England and Wales can still apply to part of your estate — particularly to immovable property like your home.

Your UK Will governs what happens to your UK-based assets, including property, bank accounts, investments, and personal belongings. Without a valid UK Will, these assets fall under the intestacy rules of England and Wales, which follow a rigid statutory formula that may bear no resemblance to your actual wishes. For example, under intestacy, unmarried partners receive nothing — regardless of how long you’ve been together. Likewise, close friends, stepchildren (who haven’t been legally adopted), and charities will receive nothing unless specifically named in a valid Will.

This guide walks you through the process of making your UK Will valid abroad, ensuring that your assets are protected and distributed according to your intentions — not left to chance or foreign court interpretation.

Key Takeaways

• Having a valid UK Will remains essential even if you’ve moved abroad — it governs your UK-situated assets.
• England and Wales apply the principle of scission: immovable property (land and buildings) is governed by the law of the country where it’s located, while movable property follows the law of your domicile.
• A UK Will covers the distribution of your UK assets, but you may need separate wills for assets held in other countries.
• Without a UK Will, the intestacy rules of England and Wales apply to your UK assets — and these rules haven’t kept pace with modern family structures.
• Specialist legal advice is essential when dealing with cross-border estates, as conflicting laws between jurisdictions can create serious problems.

Understanding International Wills

International wills are designed for individuals who hold assets in more than one country, ensuring their wishes are respected regardless of where those assets are situated. As global mobility increases — with more British families owning holiday homes, overseas investments, and foreign pensions — understanding how international wills work has become essential.

Definition and Importance

An international will is a testamentary document drafted to meet the formal validity requirements of multiple jurisdictions. It’s particularly important for anyone whose estate spans two or more countries, because each country may apply its own succession law to the assets situated within its borders.

In England and Wales, the general rule is that immovable property (land and buildings) is governed by the law of the country where the property is situated (lex situs), while movable property (bank accounts, investments, personal belongings) is governed by the law of the testator’s domicile at death. This means a UK Will typically covers UK-situated property effectively, but may not extend to foreign immovable property without careful drafting.

Making wills overseas requires an understanding of these distinctions and the legal requirements of each relevant country. With the right specialist guidance, you can ensure your international will is valid and operates as intended.

Key Differences from Standard Wills

International wills differ from standard UK Wills in several important ways. A standard UK Will must comply with the Wills Act 1837 — signed by the testator in the presence of two independent witnesses who then attest the signature. An international will must also satisfy the formal requirements of other jurisdictions, which can impose additional or different rules.

• Compliance with multiple legal systems — some countries require notarisation, others require handwritten (holographic) wills
• Tax implications across different jurisdictions — inheritance tax (IHT) in the UK, succession tax in France, estate tax in the United States, and double taxation treaties between countries
• Specific requirements for witnessing, notarising, and registering the will in each relevant country

Understanding these differences is vital when making wills overseas, as failing to comply with local formalities can render your will invalid in that jurisdiction — meaning intestacy rules apply instead.

When to Consider an International Will

You should consider creating an international will — or a coordinated set of wills for different jurisdictions — if you hold significant assets abroad, such as property in Spain or France, bank accounts in another country, or investments through foreign institutions. This is especially important if you’ve changed your domicile or habitual residence, as this can alter which country’s succession law applies to your movable estate.

An international will provides clarity and certainty, reducing the risk that your beneficiaries face expensive cross-border legal disputes. It also helps avoid the situation where a foreign court applies forced heirship rules that override your wishes — a common issue in many European and Middle Eastern jurisdictions where the testator’s freedom to distribute assets is restricted by law.

Legal Framework for International Wills

Navigating the legal landscape of international wills requires a solid understanding of the conventions and laws that govern testamentary validity across borders. Getting this right is the difference between a will that works seamlessly and one that creates years of expensive litigation for your family.

The Hague Convention and Its Impact

The Hague Convention on the Conflicts of Laws Relating to the Form of Testamentary Dispositions (1961) is the primary international instrument governing the formal validity of wills across borders. The Convention establishes that a will is formally valid if it complies with the internal law of any one of several connecting factors — including the place where the will was made, the testator’s nationality, domicile, or habitual residence, or (for immovable property) the place where the property is situated.

In practical terms, this means a UK Will that complies with the Wills Act 1837 will generally be recognised as formally valid in any country that is party to the Convention. However, formal validity is only part of the picture — the will must also be materially or substantively valid under the applicable succession law, and this is where complications often arise.

Recognised Jurisdictions

Understanding which jurisdictions are party to the Hague Convention is important for planning purposes. The following table lists some key signatory countries:

Legal Considerations in Different Countries

While the Hague Convention provides a degree of standardisation on formal validity, each country retains its own substantive succession law — and these can differ dramatically. The most significant issue for British expats is forced heirship. Many civil law countries (including France, Spain, Italy, and much of the Middle East and South America) impose mandatory shares that must pass to certain family members — typically children and sometimes spouses — regardless of what your will says.

For example, in France, if you have three children, they are collectively entitled to 75% of your estate under French forced heirship rules. You can only freely dispose of 25%. Since the EU Succession Regulation (Brussels IV), British nationals with assets in participating EU countries can elect for their national law (English law) to apply to their entire estate — which provides full testamentary freedom. However, this election must be expressly stated in your will. It is worth noting that following Brexit, the UK is no longer an EU member state, but British nationals can still make this election because Brussels IV allows a person to choose the law of their nationality, and the UK remains a recognised nationality for this purpose.

When planning your international will, consider the following:

• The succession laws of every country where you hold assets — particularly forced heirship rules
• Tax implications, including double taxation treaties between the UK and the relevant country (the UK has IHT treaties with several countries including France, India, Ireland, Italy, the Netherlands, South Africa, Switzerland, and the United States)
• Whether you should elect for English law to apply under Brussels IV or any equivalent mechanism

By taking these factors into account and working with solicitors experienced in cross-border estate planning, you can create an international will that effectively manages your global assets and minimises the risk of disputes.

Making Your UK Will Valid Overseas

To safeguard your global assets, understanding how to make your UK Will valid overseas is essential. While a properly executed UK Will has a good chance of being formally recognised in many countries thanks to the Hague Convention, there are specific steps you should take to maximise its effectiveness abroad.

Essential Requirements

Under English law, a valid Will must be in writing, signed by the testator (or by someone in their presence and at their direction), and attested by two independent witnesses who are both present at the same time. The witnesses must not be beneficiaries under the Will (or the spouse or civil partner of a beneficiary), or their gifts become void.

For international recognition, you should also consider whether the countries where your assets are held impose additional requirements. Some jurisdictions require the will to be notarised by a public notary. Others require a specific form of attestation clause that confirms compliance with local formalities. Getting these details right at the drafting stage is far easier than trying to fix problems after death.

Understanding Foreign Laws

Understanding the laws of the countries where your assets are located is essential. Different jurisdictions have varying rules regarding inheritance, taxation, and the administration of estates. Key issues to watch for include:

• Forced heirship rules — found in France, Spain, Italy, Germany, and many other civil law countries — which restrict your freedom to choose who inherits
• Matrimonial property regimes — some countries automatically treat assets acquired during marriage as jointly owned, which affects what passes under your will
• Tax residence rules — your tax obligations may differ from your domicile for succession purposes, creating a mismatch between IHT liability and succession law

Translation and Language Issues

Translation and language barriers can pose significant practical challenges. While your UK Will can be drafted in English, foreign probate authorities and courts will typically require a certified or sworn translation. In some jurisdictions, an official translation by a court-appointed translator is mandatory, and the translated version may need to be notarised.

It’s worth noting that certain legal concepts in English trust and succession law have no direct equivalent in civil law systems — for example, the concept of a trust itself is unknown in many European legal systems. England invented trust law over 800 years ago, and while trusts are one of the most powerful estate planning tools available, many jurisdictions simply don’t recognise them. This makes accurate legal translation (not just linguistic translation) critically important.

Foreign Assets and Will Validity

When your estate includes assets in more than one country, the interaction between different legal systems becomes a critical planning issue. Getting this wrong can mean your wishes are overridden, your family faces double taxation, or your estate is tied up in foreign courts for years.

Types of Foreign Assets

Foreign assets can take many forms, and each type may be treated differently by local succession and tax law. Common categories include:

• Real estate (holiday homes, investment properties, land)
• Foreign bank accounts and savings
• Overseas investments and shareholdings
• Foreign pensions (which may or may not pass under a will, depending on the scheme rules and local law — many pensions pass outside the will via a nomination or expression of wishes form)

Inheritance Tax and Cross-Border Liabilities

Inheritance tax (IHT) in the UK is charged on the worldwide estate of anyone who is UK-domiciled — regardless of where the assets are physically situated. The current IHT rate is 40% on the taxable estate above the nil rate band (NRB) of £325,000 per person (frozen since 2009 and confirmed frozen until at least April 2031). A residence nil rate band (RNRB) of £175,000 may also be available if a qualifying residential interest is passed to direct descendants — though this only applies to children, grandchildren, and stepchildren, not to nephews, nieces, siblings, or friends.

For married couples and civil partners, unused NRB and RNRB can transfer to the surviving spouse, giving a combined maximum threshold of £1,000,000 (£650,000 NRB + £350,000 RNRB) before IHT applies. However, the RNRB tapers away by £1 for every £2 the estate exceeds £2,000,000 in value.

The key cross-border tax issue is double taxation. If you hold property in France, for example, both the UK and France may seek to tax the same asset on death. The UK has double taxation treaties covering IHT with a limited number of countries (including France, India, Ireland, Italy, the Netherlands, Pakistan, South Africa, Sweden, Switzerland, and the United States). Where a treaty exists, it provides a mechanism to avoid being taxed twice on the same asset. Where no treaty exists, unilateral relief may be available under UK law — but this is less straightforward and may not fully eliminate the double charge.

Key considerations include:

• Whether a double taxation treaty exists between the UK and the country where your assets are held
• Your domicile status — UK-domiciled individuals are taxed on worldwide assets; non-UK-domiciled individuals are only taxed on UK-situated assets (though the rules on deemed domicile have been tightening, and significant changes are planned from April 2025 onwards with the move to a residence-based regime for new arrivals)
• Local taxes in the country where the asset is situated — many countries impose their own inheritance or succession tax

Implications of Multiple Jurisdictions

When your estate involves assets in multiple jurisdictions, several practical complications arise. Different courts may need to grant their own form of probate or succession authority. Executors may need to be separately appointed in each country. Time zones, language barriers, and differing procedural requirements all add delay and cost.

To mitigate these risks:

• Seek specialist legal advice from solicitors experienced in cross-border estate planning — as Mike Pugh says, “the law, like medicine, is broad — you wouldn’t want your GP doing surgery”
• Consider creating separate wills for different jurisdictions, each drafted by a local specialist but coordinated to avoid conflicts
• Ensure that your executors are aware of every asset in each jurisdiction and have the practical ability to deal with them
• Consider whether a lifetime trust might be appropriate for your UK property — assets held in trust bypass the probate process entirely, meaning trustees can act immediately without waiting for a Grant of Probate

By understanding the implications of foreign assets on your will’s validity, you can take proactive steps to ensure that your estate is managed according to your wishes — not left to the default rules of whichever country happens to apply.

Creating Separate Wills for Different Countries

Separate wills for different countries can offer a tailored approach to estate planning, addressing local laws and regulations specific to each jurisdiction. This is the approach most commonly recommended by cross-border estate planning specialists.

Advantages of Separate Wills

Creating separate wills for different countries has several concrete benefits:

• Local Law Compliance: Each will is drafted to comply with the specific formalities required by the country where those assets are situated — eliminating the risk of formal invalidity.
• Faster Administration: Executors can apply for the local equivalent of probate in each country simultaneously, rather than waiting for a UK Grant of Probate and then applying to have it recognised abroad (a process called “resealing” that isn’t available in all countries).
• Reduced Conflict: Each will deals only with the assets in its jurisdiction, minimising the risk that one country’s court misinterprets provisions intended for another jurisdiction.

Disadvantages to Consider

While having separate wills is generally the preferred approach, there are important risks to manage:

• Accidental Revocation: This is the single biggest danger. If a foreign will contains a standard revocation clause (“I revoke all previous wills”), it may inadvertently revoke your UK Will. Each will must be carefully drafted to revoke only previous wills relating to assets in that specific jurisdiction.
• Higher Costs: You’ll need solicitors in each country, which increases the overall cost. However, this is typically far less expensive than the cost of sorting out a contested or invalid cross-border estate after death.
• Coordination Required: The wills must work together as a coherent whole. Any inconsistency — such as both wills claiming to cover the same asset — creates confusion and potential litigation.

How to Draft a Separate Will

Drafting a separate will for another country requires specialist legal advice in that jurisdiction, coordinated with your UK solicitor. Here are the key steps:

By taking a coordinated and informed approach to creating separate wills for different countries, you can ensure that your international estate is managed according to your wishes and in compliance with each country’s laws.

Revocation of Existing Wills

When considering the revocation of a UK Will, it’s vital to understand the potential impact on your foreign assets and overall estate planning. This is one of the most dangerous areas in cross-border succession — an incorrectly drafted revocation can unintentionally destroy a perfectly valid will in another country.

Process of Revoking a UK Will

Under English law, a Will can be revoked in three ways: by making a new Will that expressly revokes the previous one; by a written declaration of intention to revoke, executed with the same formalities as a Will (signed and witnessed by two independent witnesses); or by physical destruction of the Will with the intention of revoking it. Additionally, marriage automatically revokes any existing Will (unless the Will was made in contemplation of that specific marriage), while divorce does not revoke a Will — it simply treats the former spouse as if they had predeceased the testator for the purposes of gifts and appointments in the Will.

Critical point for international estates: If you are making a new UK Will to replace an old one, the revocation clause must be drafted carefully. A standard clause reading “I revoke all former Wills and testamentary dispositions” could revoke your foreign wills as well, leaving assets in other countries subject to intestacy rules.

To revoke a UK Will safely when you have foreign assets:

• Use a limited revocation clause that expressly revokes only previous wills relating to assets situated in England and Wales.
• Ensure the new will is signed in the presence of two independent witnesses who are not beneficiaries.
• Inform your executors and any foreign solicitors about the change, so the overall estate plan remains coordinated.

Impact on Existing Foreign Assets

The revocation of a UK Will can have varying implications for your foreign assets, depending on the succession laws of the countries involved and how each country interprets the revocation clause. Some civil law jurisdictions may treat a broad revocation in one will as affecting all testamentary dispositions worldwide, even if that wasn’t your intention.

Consider the following common scenarios:

Legal Advice for Avoiding Conflicts

To avoid conflicts when revoking a will where international assets are involved, specialist cross-border legal advice is essential. A generalist solicitor who handles conveyancing and family law may not appreciate the nuances of how a revocation clause interacts with foreign jurisdictions. The law, like medicine, is broad — you need a specialist for this kind of work.

Key considerations include:

• Always use jurisdiction-specific revocation clauses — never a blanket “I revoke all previous wills” if you have separate wills for different countries.
• Ensure that every will in your estate plan cross-references the others, so it’s clear which will governs which assets.
• Review and update your entire estate plan whenever you acquire or dispose of assets in a new jurisdiction, or when your personal circumstances change (marriage, divorce, birth of children, change of domicile).

The Role of Executors in International Wills

Executors play a pivotal role in ensuring your international will is administered according to your wishes. When assets span multiple countries, the executor’s job becomes significantly more complex — and choosing the wrong person can result in delays, additional costs, and family disputes.

Duties of Executors Across Borders

In England and Wales, executors are responsible for applying for a Grant of Probate from the Probate Registry, collecting the deceased’s assets, paying debts and IHT, and distributing the estate to the beneficiaries. When foreign assets are involved, these duties extend across borders — and each country has its own process.

• Identifying and valuing assets in each country — which may require local valuations and currency conversions
• Applying for the local equivalent of probate in each relevant country (e.g., certificat d’hérédité in France, Erbschein in Germany)
• Managing IHT obligations in the UK (which applies to the worldwide estate of UK-domiciled individuals) as well as local succession taxes abroad
• Navigating different timescales — UK probate currently takes around 4-8 weeks for the Grant itself, but the full administration process takes 3-12 months (longer with property sales), and adding foreign jurisdictions extends this considerably

For instance, if you have assets in both the UK and France, your executor must obtain a UK Grant of Probate and separately deal with the French notaire system, which operates very differently from the English probate process. Understanding the interaction between the Hague Convention and local processes is essential.

Selecting Suitable Executors

Choosing the right executor for an international estate is one of the most important decisions you’ll make. They need to be capable of managing complex legal and financial matters across different jurisdictions — or at least willing to instruct appropriate professionals in each country.

When selecting an executor, consider:

• Their practical ability to manage affairs in multiple countries — language skills, availability to travel, and willingness to engage with foreign legal systems
• Whether appointing different executors for different jurisdictions makes more sense (some people appoint a UK executor for their UK Will and a local executor for their foreign will)
• The option of appointing a professional executor — such as a solicitor or trust corporation — who has experience with international estates, particularly if your estate is complex

Managing Assets in Different Jurisdictions

Managing assets across borders requires careful coordination between executors, solicitors, and local legal professionals in each country. The following table outlines the key considerations for some common jurisdictions:

By understanding the role of executors in international wills and choosing the right people for the job, you can ensure that your estate is administered efficiently and according to your intentions — even when your assets span multiple countries.

Practical Steps to Create an International Will

Ensuring that your will is valid and effective across borders requires careful planning and specialist guidance. Here are the practical steps to follow.

Engaging Legal Professionals

The most important step in creating an international will is engaging solicitors who specialise in cross-border estate planning. A generalist high-street solicitor may be competent to draft a straightforward UK Will, but international estates require specialist knowledge of how different legal systems interact.

When selecting a solicitor, look for someone with a proven track record in handling international estates. They should be well-versed in the succession laws of the countries where you have significant assets and be able to coordinate with local legal professionals abroad. If you also need to protect your UK home through a lifetime trust or updated estate plan, ensure your adviser understands how trusts interact with your international arrangements — particularly since trusts are a uniquely common-law concept that may not be recognised in civil law jurisdictions where you hold assets.

Document Preparation and Storage

Proper document preparation is vital for an international will. This includes:

• Drafting a clear and unambiguous will that precisely identifies which assets it covers and which it does not.
• Including an express election for English law to govern your succession if you hold assets in EU countries that participate in Brussels IV.
• Having the will translated by a certified legal translator if required by the relevant foreign jurisdiction.

Storage of the will is also a critical consideration. The original UK Will should be stored securely — many solicitors offer safe storage, and some clients use their bank’s safe custody service. Your executors must know exactly where to find it. If you have separate wills for different countries, each original should be stored in the relevant jurisdiction, with copies held by your UK solicitor so they can see the full picture. A comprehensive schedule listing all wills, their locations, and the solicitors involved in each country should be provided to your executors.

Notarisation and Witnessing Requirements

The formal requirements for executing a will vary significantly between jurisdictions. In England and Wales, a Will must be signed by the testator in the presence of two independent witnesses, both present at the same time, who then attest the signature. No notarisation is required for a UK Will, though remote witnessing via video link is now permanently available in certain circumstances following the changes introduced during the Covid-19 pandemic.

However, many civil law countries (including France, Spain, Italy, and Germany) require notarisation — meaning the will must be executed before a public notary. Some jurisdictions require the will to be read aloud, translated on the spot, or deposited with a public registry.

To ensure your will is valid in each relevant country, you must comply with the specific notarisation and witnessing requirements of that jurisdiction. Your cross-border estate planning solicitor should coordinate this, ensuring that each will meets local formalities without inadvertently conflicting with another.

Potential Challenges with International Wills

The complexities of international wills can create significant challenges — from conflicting succession laws to practical administration issues. Understanding these hurdles in advance allows you to address them proactively rather than leaving problems for your executors and beneficiaries to resolve after your death.

Navigating Conflicting Laws

One of the primary challenges with international wills is the conflict between different countries’ succession laws. A will that is perfectly valid in England and Wales may produce unexpected results — or be partially overridden — in another jurisdiction. The most common source of conflict is between the English principle of testamentary freedom (you can leave your estate to whoever you wish) and the forced heirship rules that apply in most civil law countries.

For example, a UK resident who owns a holiday home in France may wish to leave everything to their spouse. Under English law, this is straightforward. But under French law, if they have children, those children have a mandatory right to a share of the French property — and no will can override this unless the testator has expressly elected for English law under Brussels IV.

Dealing with Different Legal Systems

Different countries operate fundamentally different legal systems, which can complicate the creation and execution of an international will. Understanding these structural differences is essential to ensure that your will is valid and enforceable in each relevant country.

• Common law systems (England and Wales, Australia, Canada, parts of the US) — rely heavily on judicial precedent and generally allow full testamentary freedom. England and Wales also have the Inheritance (Provision for Family and Dependants) Act 1975, which allows certain categories of people to challenge a will if it doesn’t make “reasonable financial provision” for them — but this is much more limited than civil law forced heirship.
• Civil law systems (France, Germany, Spain, Italy, most of continental Europe) — governed by codified laws with forced heirship rules that restrict testamentary freedom.
• Sharia-based systems (many Middle Eastern and North African countries) — apply Islamic succession rules with fixed shares for family members, often regardless of what a will says.

Being aware of these distinctions at the planning stage allows you to draft wills that work within each system rather than against it.

Common Issues Faced by Testators

Testators with international estates commonly encounter several practical issues:

1. Accidental revocation — a new will in one country inadvertently revokes a valid will in another country through a broad revocation clause.
2. Conflicting forced heirship rules — different countries’ mandatory inheritance shares creating competing claims on the same assets.
3. Double taxation — being taxed on the same assets by two countries, particularly where no double taxation treaty exists.
4. Recognition and enforcement difficulties — some countries may not recognise a Grant of Probate from England and Wales, requiring a separate local process.
5. Trust recognition — if your UK estate plan includes a lifetime trust, many civil law jurisdictions do not recognise trusts as a legal concept, which can create complications for assets held on trust in those countries.

The key to a successful international will is not just understanding the laws, but anticipating potential conflicts and addressing them proactively. Working with specialist cross-border solicitors — ideally coordinated from your UK base — is the most effective way to identify and resolve these issues before they become problems for your family. Plan, don’t panic — but do plan proactively.

Finalising and Validating Your Will Abroad

The process of finalising and validating your will abroad involves several key steps that are crucial for the smooth administration of your estate across multiple jurisdictions.

Steps to Ensure Validity

To ensure the validity of your will in each relevant country, you need to satisfy both the formal requirements (how the will is executed) and the substantive requirements (what the will can and cannot do under local succession law). In practice, this means:

• Reviewing the formal execution requirements for each relevant country — number of witnesses, notarisation, language, registration.
• Ensuring that your will’s provisions are compatible with local succession law — particularly forced heirship rules.
• Including appropriate elections (such as an election for English law under Brussels IV) where available and beneficial.

Final Review with Legal Experts

A final review with solicitors in each relevant jurisdiction is essential before execution. These professionals can identify potential conflicts between your wills, flag issues with local succession law, and ensure that the documents work together as a coherent whole. This is not an area for DIY estate planning — the consequences of getting it wrong can be severe and expensive.

For more information on creating an effective estate plan that works both in the UK and internationally, visit MP Estate Planning for specialist guidance.

Communicating Intentions to Heirs

Communicating your intentions to your beneficiaries is an often-overlooked but important part of international estate planning. When assets span multiple countries and are governed by separate wills, the potential for confusion and family disputes increases significantly.

We recommend discussing your plans with your beneficiaries in broad terms — explaining which assets are where, which solicitors are involved in each country, and where the original documents are stored. You don’t need to disclose every detail, but ensuring your family understands the overall structure can prevent misunderstandings and speed up the administration process when the time comes. A letter of wishes, kept alongside your will, can also provide helpful context for your executors — particularly for discretionary decisions about how and when to distribute assets.

The Future of International Wills

The landscape of international estate planning is evolving rapidly, driven by increasing global mobility, changing tax rules, and technological innovation. Staying informed about these developments is essential for anyone with cross-border assets.

Trends in Global Estate Planning

Several significant trends are shaping the future of international wills and estate planning:

• Increasing use of lifetime trusts — England invented trust law over 800 years ago, and trusts remain one of the most effective tools for managing assets, providing protection against care fees, divorce, and sideways disinheritance, and achieving tax efficiency. However, trusts are not recognised in many civil law jurisdictions, creating ongoing challenges for cross-border planning. For UK-based assets, a well-structured lifetime trust — such as a discretionary trust — can bypass probate delays entirely, as trustees can act immediately without waiting for a Grant.
• Greater scrutiny of international tax arrangements — HMRC and tax authorities worldwide are sharing more information than ever through mechanisms like the Common Reporting Standard (CRS), making it essential that international estates are structured transparently and in full compliance with all applicable tax laws.
• Frozen UK tax thresholds — the IHT nil rate band has been frozen at £325,000 since 2009 and won’t increase until at least April 2031. Meanwhile, the average home in England is now worth around £290,000, meaning more ordinary families are being caught by IHT — making both international and domestic estate planning more important than ever for British expats and residents alike.
• Upcoming changes to pensions and IHT — from April 2027, inherited pensions are set to become liable for IHT, which will significantly affect cross-border estate planning for anyone with UK pensions or SIPPs.

Impact of Technology on Will Creation

Technology is changing how wills are created, stored, and administered, though progress varies significantly between jurisdictions:

• Digital wills registers — some countries are developing centralised registers to record the existence (not the content) of wills, making it easier for executors to locate testamentary documents
• Remote witnessing — temporarily permitted in England and Wales during the Covid-19 pandemic and subsequently made permanent, allowing wills to be witnessed via video link in certain circumstances
• AI-assisted estate analysis — tools like MP Estate Planning’s Estate Pro AI can identify potential threats to your estate by analysing your specific circumstances against current UK law, though complex cross-border matters still require specialist human judgement

Predictions for Will Legislation

Legislation surrounding international wills is likely to evolve as governments respond to increasing global mobility and cross-border asset ownership:

As these changes unfold, it’s essential for anyone with international assets to review their estate plan regularly and ensure it remains effective under current law. Plan, don’t panic — but do plan proactively.

Resources for International Will Creation

Creating an international will is a specialist task that requires the right professional support. The following resources can help you navigate the process of making wills overseas and ensuring will validity in different countries.

Expert Guidance

The most valuable resource is a solicitor who specialises in cross-border estate planning. Look for practitioners with membership of specialist bodies such as STEP (the Society of Trust and Estate Practitioners), which indicates expertise in trusts and estates. For your UK estate planning needs — including lifetime trusts to protect your home and assets from care fees, divorce, and inheritance tax — MP Estate Planning can provide specialist guidance. As Mike Pugh puts it, “trusts are not just for the rich — they’re for the smart.” The same applies to international estate planning: it’s about being informed, proactive, and properly advised.

Estate Planning Organisations

Several professional organisations can help you find qualified advisers and provide educational resources:

• STEP (Society of Trust and Estate Practitioners) — the leading global professional body for trust and estate practitioners, with members in over 95 countries
• The Law Society of England and Wales — maintains a directory of solicitors with international expertise
• IBA (International Bar Association) — provides resources on cross-border legal issues

Online Tools and Resources

While online tools can be useful for initial research and organisation, cross-border estate planning is not an area where DIY solutions are advisable. The interaction between different countries’ laws is too complex and the consequences of getting it wrong are too severe. Use online resources to educate yourself, but always engage specialist solicitors for the actual drafting and execution of your wills.

By leveraging the right professional resources, you can create a comprehensive and coordinated set of international wills that protect your assets and ensure your wishes are respected — wherever in the world those assets are held. Not losing the family money provides the greatest peace of mind above all else — and that applies whether your assets are in one country or ten.