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Cross-Border Wills Guide

A comprehensive guide to making your will work across borders as a UK expat. Covers EU Succession Regulation, multiple wills strategy, forced heirship rules, digital assets and UK probate for non-residents.

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Will planning checklist

Track your progress on essential will planning steps.

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Will strategy guide

EU Succession Regulation (Brussels IV)

Forced heirship rules by country

🇫🇷 France

Reserved portion: 1 child = 50%, 2 children = 66%, 3+ children = 75%. Spouses may only receive the income of the estate (usufruit) unless given full ownership by election. Brussels IV allows UK citizens to elect UK law to apply.

🇪🇸 Spain

Compulsory portions for children: 2/3 of estate (1/3 strict, 1/3 improvement, 1/3 free). Spouses have a usufruct right. Regional laws (Catalonia, Basque Country etc.) vary. Brussels IV nationality election available for UK nationals.

🇩🇪 Germany

Compulsory share (Pflichtteil): half the statutory entitlement in value. Children, parents and spouses can claim. Brussels IV applies — UK nationals may elect UK law.

🇦🇪 UAE

Sharia law default for Muslims. Non-Muslims may register a will with the DIFC Wills Service Centre or Abu Dhabi Judicial Department. Without registration, UAE law applies to UAE assets, which may not align with your intentions.

🇹🇭 Thailand

Foreigners cannot own land. Condo/leasehold interests can pass by Thai will. Register a Thai will with the Amphoe (district office). UK will has limited effect on Thai assets.

🇦🇺 Australia

Testamentary freedom but courts can order provision for dependants (Family Provision Claims). AU assets generally governed by AU law regardless of UK will. Consider dual wills.

Multiple wills strategy

Digital assets

Full cross-border estate planning guidance — Premium required.

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