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Wills don’t travel, and neither do the rules behind them

A general overview, not legal advice, of how will rules vary between countries and which cross-border rules decide the law that applies

Globe representing global will jurisdictionsGlobe representing global will jurisdictions

Three legal traditions

Most of the world’s wills fall into one of three legal families

Common-law

Descended from the Wills Act 1837: a written will and two witnesses, no notary. Used across much of the Commonwealth and the US.

Civil-law

Usually signed before a notary, who keeps the original. Common in continental Europe and Latin America, often with forced-heirship shares for children.

Mixed / holographic

Handwritten, signed wills with no witnesses. Accepted in many US states, France and Spain; others allow them only in emergencies, or not at all.

This is a general overview, not legal advice. Specific rules vary by jurisdiction. Consult a qualified professional in yours.

Legal traditions illustration

Frequently asked questions

Start a will in your jurisdiction

Begin with the rules of the place you live, and read the guides for anywhere else you are connected to

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