Tool · succession
Cross-border Succession Navigator
When the testator, the heir and the assets sit in different countries, an estate is split across several laws at once — with different forced shares, taxes and procedures.
Testator
Citizenship · one or more
Residency · one or more
Heir
Residency · one or more
Assets
Frequently asked questions
Which law governs succession when the parties live in different countries?
Money and accounts are usually inherited by the law of the country where the testator lived; real estate follows the law of the country where it sits. In the EU a single rule applies (Regulation 650/2012), and you can choose the law of nationality in the will in advance.
What is forced heirship?
In several countries the law firmly reserves part of the estate for close relatives — they cannot be disinherited by will. In the UK and US, by contrast, testamentary freedom applies.
What if a person holds several residence permits?
Then more than one country may claim tax and applicable law at once. It is important to determine the main place of residence (centre of life) and account for double-tax treaties — the navigator flags this risk.
Related articles
This is general guidance, not legal advice: the rules are simplified so you grasp the picture and know what to check. A lawyer will give the exact picture for your assets and family.
Contact information
If you have questions or need a consultation, our experts will be glad to help.