A holiday apartment in Portugal, a pension pot left behind after a posting in Germany, a brokerage account opened during a few years in the United States: assets tend to collect in different countries over a working life. Each of them sits under its own rules, and when the owner dies, those rules do not automatically agree with one another. Planning ahead is what turns a potential tangle into a process heirs can actually manage.
Start with a map of what you own and where
Before any legal document is drafted, it helps to write down every asset together with the country it is located in, how it is held (sole name, joint name, through a company) and who currently knows about it. This inventory is the backbone of everything else. It shows which legal systems are involved and often reveals forgotten items, such as a dormant savings account or a small plot of inherited land.
Keep the list somewhere your executor can find it, along with copies of deeds, account statements and policy documents. A clear paper trail saves heirs from writing to foreign banks with little more than a name and a guess.
Why the rules of different countries collide
Inheritance law is built on very different ideas around the world. Some countries let you leave property to whoever you choose, while others reserve fixed shares for children or a spouse. Some decide which law applies based on nationality, others on habitual residence, and real estate is frequently governed by the law of the place where it stands. Tax rules add another layer, because more than one country may consider itself entitled to tax the same estate.
These differences are exactly why many families bring in an international inheritance lawyer early on. Someone who works across jurisdictions can explain which law is likely to apply to each asset, where forced heirship might override your wishes, and how to structure documents so they are recognised in every country involved.
One will or several?
There is no single right answer. A single will covering everything is simpler to keep up to date, but it may need to be translated, certified and accepted by courts abroad. Separate wills for separate countries can speed up local probate, yet they must be drafted with care so that a newer will does not accidentally cancel an older one in another jurisdiction.
- Make sure each will refers clearly to the assets it covers and to the existence of the others.
- Use consistent names, dates and definitions across all documents.
- Review every will together whenever you buy, sell or move.
Trusts, ownership structures and beneficiary designations
Some assets pass outside a will altogether. Life insurance policies, certain pension schemes and accounts with named beneficiaries go directly to the person listed, which can be faster than probate. Trusts can also hold property and set out how it should be managed, although not every country recognises them in the same way, and their tax treatment varies widely. Whether a trust, a joint ownership arrangement or a holding company makes sense depends entirely on your circumstances, so these options are worth discussing with qualified legal and tax advisers rather than copying what worked for someone else.
Keep the plan alive
An inheritance plan is not a one-off task. Marriages, divorces, new children, a change of residence or a property sale can all shift which law applies and what your documents should say. A short annual check, plus a fuller review after any major life event, keeps everything aligned. Talking openly with your family about where documents are kept and who your advisers are also matters: the best-drafted plan helps no one if the people who need it cannot find it.
