Multi-Jurisdiction Wills
Educational guides for people whose lives, families or assets span more than one country
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These pages are general information, not legal or tax advice. Rules vary significantly by jurisdiction. For your specific situation, please consult a qualified legal or tax professional.
Why cross-border situations are different
When you live, work, hold citizenship or own assets in more than one country, the question of which country’s rules apply to your estate becomes a real one. Different countries take different approaches to who inherits, what counts as part of an estate, how assets transfer on death, and which courts decide. The aim of this section is to introduce the concepts so you can ask better questions of professionals, not to recommend an outcome.
Topics in this section
Domicile vs tax residence
Citizenship, tax residence, domicile and habitual residence are different concepts: here is how they relate and why the distinction matters for your will
Asset types across borders
How moveable, immoveable, intangible and financial assets can be treated differently in different countries
Community vs professional
When the community forum can help and when it makes sense to speak to a qualified professional
Cross-border tax planning
General information about how tax considerations can change when assets and people span more than one country
Worked scenarios
Anonymised cross-border situations and the questions they tend to raise: general information, not advice
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