Holding a new residency or citizenship often means assets and family span two legal systems. This guide explains the succession issues that arise across borders and the questions to put to a qualified professional.
Information, not advice. Figures are indicative and current as of June 2026. Always confirm the present rules with the official program authority and a licensed professional before you act.
The moment your life touches two countries, two legal systems may have something to say about your estate. They can disagree on who inherits, which law governs, and who taxes what. The goal of planning is to remove that uncertainty in advance, so your wishes are not undone by a conflict you never saw coming.
A first step is to map where your assets sit, which countries claim a connection to you, and on what basis they claim it, whether citizenship, domicile, residence, or the location of an asset.
Many civil law countries apply forced heirship, which reserves a fixed share of an estate for certain relatives such as a spouse and children, regardless of what a will says. If your plan assumes you can leave assets freely, a forced heirship rule in the second country can override it. Some systems allow a person to elect the law of their nationality to govern their estate, which can change this result, but the conditions are specific and must be set up correctly.
Real estate is generally governed by the law of the place where it sits, often described as the law of the situs. That means a property abroad can fall under local inheritance rules even if your main will sits elsewhere. A common response is to use more than one will, with a separate document for the assets in each country. Done carefully this can speed local probate and tailor each will to local law. Done carelessly, a later will can accidentally revoke an earlier one, so coordination between professionals in both countries matters.
When two countries both assert taxing rights on death, an estate can face double taxation unless relief or a treaty applies. Effective planning starts by identifying which jurisdictions tax the estate and on what basis, then looks for reliefs, treaty provisions, and structures that reduce overlap. Because these rules are technical and country specific, this is an area to handle with qualified legal and tax professionals in both jurisdictions rather than a single general adviser.
Often it helps, because a will tailored to local law can simplify probate where an asset sits. But multiple wills must be drafted to work together so a later one does not revoke an earlier one by accident. Use coordinated professionals in each jurisdiction and confirm the approach with them before signing.
Sometimes. Certain systems allow you to elect the law of your nationality to govern your estate, which may displace local forced heirship. The conditions are specific and vary by country, so this must be set up correctly with qualified legal advice rather than assumed.
Start by identifying which countries tax the estate and on what basis, then look for reliefs and any treaty between them. Whether double taxation arises and how it is relieved depends on the specific countries and assets, so confirm your position with tax professionals in both jurisdictions.
Information, not advice. Figures are indicative and current as of June 2026. Always confirm the present rules with the official program authority and a licensed professional before you act.
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