When a person dies holding assets across two or more jurisdictions, every legal system involved has its own rules — on capacity, on formality, on what passes under a will and what does not. We coordinate the process, engaging local counsel where needed and maintaining clear oversight so that nothing falls between the gaps.
Estates that cross borders require practitioners who understand what changes — and what does not — at each one.
Many estates have a global dimension. A person may have lived in one country while holding property in others. An expatriate may have pension rights in one country, real estate in another, and financial accounts in a third.
Legal systems differ in how they decide which law governs an estate. Some distinguish between moveable property — such as bank accounts, investments and company shares — and immoveable property such as land, and use connecting factors such as domicile, nationality, habitual residence or the place where an asset is located. Understanding how each relevant jurisdiction approaches these questions, and how they may differ from one another, is central to advising on an international estate correctly.
We manage the whole matter or act alongside foreign counsel, depending on what the estate requires. Where local proceedings are needed in another jurisdiction, we brief and coordinate appropriate practitioners, monitor progress, and ensure that the overall administration remains coherent.
"The difficulty in international estates is rarely any one legal question. It is the interaction between several legal systems, each making different assumptions about the same underlying facts."
From domicile analysis at the outset to final asset repatriation, we handle every stage of the international administration process.
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Cross-Border Probate
We advise on the grants and formal steps that may be required in each relevant jurisdiction, and on whether and how a grant obtained in one place may be recognised or used in another. Requirements vary by jurisdiction and depend on the location of assets and the applicable procedures.
Coordination of grant applications across jurisdictions
Resealing of Commonwealth and foreign grants
Recognition of grants in other jurisdictions
Parallel administration in multiple jurisdictions
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Domicile & Succession Law Analysis
The determination of domicile at death is one of the most consequential steps in an international estate — it governs which law applies to the distribution of moveable assets and will often determine whether the deceased's will is recognised at all. We provide thorough analysis of domicile evidence and the succession law implications in each relevant jurisdiction.
Domicile of origin, choice, and dependency
Renvoi and conflicts of law
Foreign forced heirship and reserved shares
Characterisation of assets — moveable vs immoveable
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Overseas Asset Administration
We identify, collect, and transfer assets held abroad — including bank accounts, investment portfolios, real property, business interests, and pension entitlements. Where assets are held in complex holding structures or nominee arrangements, we conduct the necessary due diligence to establish beneficial ownership and trace the correct line of title.
Asset identification and valuation
Foreign bank and investment account closure
Overseas property transfer and sale coordination
Business interest realisation and transfer
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International Beneficiary Representation
We act for beneficiaries who live in one jurisdiction and have an interest in an estate administered in another, advising on entitlement under unfamiliar succession laws and, where appropriate, coordinating with local counsel on challenging improper exclusion and on bringing assets back to the beneficiary’s home jurisdiction.
Beneficiary entitlement analysis under foreign law
Foreign grant challenge and independent legal advice
Asset repatriation
Estate accounting review and dispute
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Multi-Jurisdictional Coordination
Where an estate requires formal proceedings in more than one country, we coordinate the overall administration — maintaining the timeline, managing foreign counsel, and ensuring that steps taken in one jurisdiction do not create problems in another. We provide a single point of contact for families who would otherwise need to manage multiple solicitor relationships in parallel.
Foreign counsel selection and briefing
Cross-border timeline management
Unified family and executor reporting
Tax and duty coordination across jurisdictions
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International Will Preparation
We advise on and draft wills that are designed to function across multiple jurisdictions — including jurisdiction-specific wills for particular asset pools, international wills under the UNIDROIT Convention where applicable, and guidance on whether a single will or multiple wills better serves the estate structure. We also review existing wills for international validity before assets are acquired abroad.
Multi-jurisdiction will structures
Jurisdiction-specific wills for overseas property
International will validity review
Capacity and formal validity analysis
How We Work
The international estate process.
Every cross-border estate is different, but the questions that need to be answered follow a consistent sequence. We work through them methodically — in the right order, without skipping steps that create problems later.
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Asset mapping and domicile review
We begin by identifying every jurisdiction where the deceased held assets or had a meaningful connection. Simultaneously, we analyse the evidence bearing on domicile — country of birth, history of residence, intentions to settle, and any declarations the deceased made. This analysis determines which succession law governs moveable assets and identifies which jurisdictions will require separate proceedings.
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Will validity and recognition
We assess whether the will is formally valid in each relevant jurisdiction — checking execution requirements, witness rules, capacity standards, and the effect of marriage or subsequent events on validity. Where the will may not be recognised in a foreign country, we advise on the implications and the steps needed to address this before administration begins.
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Grant strategy and sequencing
We determine which jurisdiction should issue the primary grant and in what sequence ancillary grants or resealing applications should follow. Sequencing matters: obtaining a grant in the wrong jurisdiction first can create difficulty resealing it elsewhere, and some jurisdictions will not issue ancillary grants without sight of a primary grant from the country of domicile.
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Foreign counsel coordination
Where proceedings are required in other jurisdictions, we identify suitable local practitioners, provide a consistent brief, and maintain oversight of progress. We translate the overall administration plan into instructions that each foreign counsel can act on, and we consolidate their updates for reporting to the executor and family. The executor has one team to speak to — ours.
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Asset collection and distribution
With grants in place, we coordinate the collection of assets in each jurisdiction — working with banks, investment custodians, land registries, and corporate registrars as appropriate. Collected assets are transferred to the estate and ultimately distributed to beneficiaries in accordance with the applicable succession law, with full accounting provided throughout.
Our Clients
Who we act for.
International estate matters arise across a wide range of client circumstances. We act for individuals and families wherever their connections lie.
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Executors and Administrators
Individuals appointed to administer an estate that has assets in multiple countries face an exceptionally complex task — particularly if they are unfamiliar with the legal systems involved. We provide practical, coordinated support so that executors can fulfil their obligations without becoming lost in the procedural requirements of each jurisdiction.
Multi-jurisdiction grant applications
Foreign asset collection and remittance
Executor liability and indemnity advice
Estate accounts and final distribution
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Families with Overseas Assets
High-net-worth families with property or investments in multiple countries often discover after a death that their succession arrangements do not function as intended across all jurisdictions. We advise families on what they face and how best to proceed — both in administering the current estate and in restructuring for the future to avoid the same difficulty arising again.
Estate mapping and administration strategy
Beneficiary entitlement analysis
Post-administration succession restructuring
International will review and redrafting
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Overseas Beneficiaries
Where a beneficiary lives in a different jurisdiction from the one in which an estate is administered, the practical and legal barriers to receiving an inheritance can be substantial. We advise overseas beneficiaries on their rights, represent them in the administration, and where necessary challenge the conduct of an executor or administrator acting improperly.
Entitlement analysis under the applicable succession law
Independent legal advice on renunciation or variation
Estate accounting challenge
Asset repatriation and currency matters
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Corporate Trustees and Financial Institutions
We act for professional trustees, trust companies, and financial institutions that hold assets on behalf of international estates — advising on their obligations under the applicable law, the recognition of foreign grants, and the process for releasing assets to beneficiaries or successor trustees once appropriate documentation is in place.
Foreign grant recognition and resealing advice
Documentation review for asset release
Trustee obligations under the applicable law
Indemnity and liability analysis
The deceased held bank accounts in a country where they were not domiciled. Do we need to apply to a court there?
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Often, yes. Financial institutions commonly require sight of a grant of representation recognised in their own jurisdiction before releasing funds. Whether a grant obtained elsewhere can be recognised or resealed, or whether a fresh local grant is needed, depends on the jurisdiction concerned and its procedures. We advise on the requirements in each jurisdiction and coordinate with local counsel.
The estate includes property in more than one country. Which law governs who inherits?
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The answer depends on the type of asset, where it is located, and the connecting factors used by each legal system involved. Some systems apply the law of the place where land is situated to immoveable property, and the law of the deceased’s domicile, nationality or habitual residence to moveable assets; others take different approaches. The rules differ by jurisdiction, so the position for each asset should be confirmed with local advisers. We coordinate this analysis across the jurisdictions involved.
The deceased made a will in one country. Will it be valid in another?
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Not necessarily. Many jurisdictions have rules about when a will made elsewhere will be treated as formally valid, but these differ, and formal validity is distinct from the effect of a will, which may still be challenged or varied under local law. Whether a foreign will can be admitted to probate in a given jurisdiction depends on that jurisdiction’s rules. We advise on the position in each relevant jurisdiction.
A family member died without a will, with assets in more than one country. How do we proceed?
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This is a common and genuinely complex situation. Each jurisdiction may apply its own intestacy rules, and a grant obtained in one jurisdiction will not necessarily be recognised in another. Local counsel will usually be needed in each place where assets are held, and the sequencing of proceedings can affect how quickly assets can be accessed. We coordinate the processes and advise on the most efficient sequencing.
How long does international estate administration typically take?
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It varies considerably. Timelines depend on the number of jurisdictions involved, the complexity of the assets, whether the will is contested, and the pace of foreign courts and registries, which is often outside our control. We set realistic timelines at the outset and provide clear reporting throughout so that the family always knows where matters stand and what the current bottleneck is.
Can a will made in one country deal with property located in another?
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A will can express a person’s wishes regarding foreign property, and in many cases those wishes will be given effect — but this is not guaranteed. The foreign jurisdiction may have its own formality requirements, may not recognise the grant, or may apply mandatory provisions (such as forced heirship rules or spousal rights) that override the will. For significant foreign real estate in particular, it can be worth preparing a will specific to the country where the property is situated, drafted alongside the main will so that the two do not inadvertently revoke each other. Local advice is essential.
We are beneficiaries overseas and the executor has not communicated with us for over a year. What can we do?
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Beneficiaries — wherever located — will often be entitled to information about the administration of an estate in which they are interested, though the rules differ by jurisdiction. An executor who fails without good reason to account to beneficiaries or to progress the administration within a reasonable period may be in breach of their duties. We can write to the executor requesting an estate account and a timeline for completion and, if necessary, advise on applying to the relevant court. Where there is evidence of misconduct or misappropriation, more urgent relief may be available.
Get in Touch
Speak with a solicitor about your international estate matter.
International estates involve complexity that benefits from early advice. The sooner we understand the full picture — assets, domicile, family structure — the better placed we are to advise you on what is needed and in what order.
Building No, Oval Office Tower 10F, 1 Street 360, Phnom Penh 121301, Cambodia
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