When someone dies owning assets in more than one country, the estate becomes international in nature and the legal position can become more complex very quickly.
Different legal systems apply. Different tax authorities are involved. Different procedural steps may run in parallel.
What might otherwise be a straightforward probate matter can require careful coordination across jurisdictions, particularly for executors who are already managing practical and emotional pressures.
Our work as international probate solicitors involves leading on the English probate and inheritance tax framework in estates that span more than one country. We ensure that the requirements of England and Wales are handled correctly, the appropriate grant is obtained and UK tax reporting is properly addressed.
Where other jurisdictions are involved, we work alongside a trusted network of foreign lawyers and advisers. This ensures the overall administration remains aligned and properly coordinated, rather than fragmented across countries.
The priority is to establish the correct jurisdictional route at an early stage, align the English probate position with overseas steps and reduce the risk of delay or duplication.
With clear legal direction from the outset, estates with international elements – including high-value portfolios, business interests and international property holdings – can be administered in a controlled and proportionate manner.
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Cross-border estates require early legal analysis and a clear strategy. The interaction between domicile, tax exposure and jurisdiction can materially affect how an estate is administered and distributed.
Common issues include:
If these issues are not addressed at the outset, executors can face delay, duplicated administration, inconsistent advice or personal exposure to tax or reporting errors.
We provide structured English probate advice and ensure the English process sits properly alongside any steps being taken in other countries.
This includes:
Call us on 0808 2562 917 or
We act for UK-based executors dealing with overseas assets and for international families who need specialist English probate advice.
As international probate solicitors based in London and Kent, we advise on estates with international dimensions, including high-value and complex structures. We are Lexcel-accredited and experienced in working alongside overseas advisers to ensure the English position is managed correctly.
Clients value our:
When an estate includes overseas assets, property or other international elements, careful legal and tax analysis is essential from the outset. Our international probate solicitors provide clear, strategic guidance for executors managing cross-border estates.
Contact our private client team to discuss the estate and receive clear advice on the next steps.
Can there be different wills in different countries?
Yes. It is common for individuals with assets in multiple jurisdictions to have separate wills. These must be reviewed carefully to ensure one does not unintentionally revoke another or create conflict. We analyse how the documents operate together before progressing the English probate application.
Do I need probate in England if the deceased lived abroad?
Possibly. If the deceased owned assets in England and Wales, such as property, bank accounts or shares, an English grant of probate or letters of administration may still be required. As international probate solicitors, we assess whether a full English application is needed or whether a foreign grant can be recognised here.
How does inheritance tax apply to international estates?
Inheritance tax depends largely on domicile. If the deceased was UK domiciled, worldwide assets may fall within the UK tax net. If not, generally only UK-based assets are taxable here. International estates can also raise double taxation considerations. International probate solicitors will review domicile carefully and coordinate with overseas advisers to ensure tax reporting is accurate and aligned.
What if foreign succession rules affect the estate?
Some countries operate forced heirship regimes which may restrict how certain assets pass, regardless of what an English will says. For example, in France, fixed shares of an estate may automatically pass to children. Whether those rules apply depends on the location of the asset and the governing law. We secure the English probate position and coordinate with trusted overseas advisers to ensure consistency. Careful will drafting and estate planning during lifetime can often help anticipate and manage these cross-border issues.
What is domicile and why does it matter in international probate?
Domicile is a legal concept that determines which country is regarded as your permanent home for legal and tax purposes. It is not the same as residence (where you live) or nationality (your citizenship). There are three main types: domicile of origin (usually acquired at birth), domicile of choice (acquired by settling permanently in another country) and deemed domicile (a tax concept applying after long UK residence). In international probate matters, domicile affects inheritance tax exposure and which succession rules may apply.
What is resealing a foreign grant of probate?
Resealing allows certain foreign grants of representation to be recognised by the Probate Registry in England and Wales. Not all jurisdictions qualify. Where available, it can simplify the process by avoiding a fresh application. We advise on whether resealing is appropriate and ensure the English legal requirements are met before assets are dealt with.
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Please note we cannot offer legal aid.
