Cross Border Succession and Probate

We can navigate you through the difficulties which may arise from having assets in jurisdictions outside your normal country of residence.

Complications can arise when an individual is a resident in one country, but domiciled or a national in another or owns assets in more than one jurisdiction. As different countries recognise different laws which determine succession, it is necessary to consider how different countries’ laws interact and for probate (or its equivalent) to be obtained in both/all countries where the assets are situated.

We offer advice on the most efficient way of managing cross-border assets, particularly where conflicting national laws apply, and how best to preserve your wealth for future generations.

Cross border succession and tax issues include

  • Arranging affidavits of foreign law
  • Domicile, residence and nationality
  • Double Taxation Treaties and unilateral tax reliefs
  • Estate, gift and inheritance taxes
  • Forced heirship rights
  • International estate administration
  • Obtaining letters of administration or grants of probate
  • Private International Law and conflicts of law
  • Resealing foreign grants of representation
  • Tracing beneficiaries
  • Will preparation

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