Key considerations and practical steps for dealing with international assets when someone dies

Insight

20.01.2026

In a globally mobile world, ultra-high net worth individuals are more likely than ever to hold assets and maintain personal ties across multiple jurisdictions. When someone with these types of complex arrangements dies, dealing with their international assets requires careful navigation of divergent succession laws, tax regimes, and procedural frameworks.

These complexities can have a significant impact on how an estate is administered and the sequence in which assets are dealt with. We advise individuals, family offices and trustees on the administration of cross-border estates, coordinating international legal and tax advice, managing practical steps, and handling the UK probate aspects.

Our experience of navigating these issues has led us to create this high-level guide, which outlines some of the key legal and practical considerations involved in dealing with international assets when a person dies.

Step 1: take initial practical steps

While the legal considerations set out below will guide the overall strategy, the following steps will be required at the outset when dealing with the administration of a cross-border estate:

Identify global assets

Notify financial institutions and request date-of-death valuations.
Arrange valuations for real estate, luxury assets (eg yachts, aircraft), and personal collections.
Compile a detailed inventory of global assets and liabilities, noting jurisdiction and value.
Track jurisdiction-specific deadlines for tax filings and payments.

Ascertain applicable jurisdictions and laws

Determine the deceased’s domicile (relevant for moveable assets under common law).
Confirm the place of the deceased's habitual residence (often the test under civil law systems).
Locate and review all wills, assessing validity and interaction.
Obtain legal advice in each jurisdiction to confirm applicable succession laws.
Coordinate advice to resolve any conflicts and ensure a coherent administration strategy.

Step 2: take advice on key legal considerations

When obtaining legal advice in the relevant jurisdictions, the following factors will often be relevant:

Succession laws

Multiple wills: are there separate wills for different jurisdictions? Are they valid and coordinated?
Testamentary freedom: do the relevant jurisdictions permit full freedom to dispose of assets?
Forced heirship: do any of the relevant jurisdictions have mandatory inheritance rules affecting asset distribution?
Matrimonial property regimes: how are assets classified between spouses?
Real estate: in most cases passes under the laws of the jurisdiction where it is located.
Moveable assets: typically governed by the law of the deceased’s domicile (or habitual residence).
Choice of law election: has one been made and how does it impact the above considerations?

Tax regimes

Estate and inheritance tax: what taxes apply in each jurisdiction and what are the relevant deadlines for payment?
Worldwide tax exposure: are global assets subject to tax in multiple jurisdictions?
Double tax treaties: do treaties exist to mitigate double taxation?
Unilateral relief: is relief available where no treaty applies?

Procedural requirements

Automatic inheritance: do assets pass automatically under local law?
Probate applications: is a grant of representation required?
Re-seal applications: can foreign grants be recognised or re-sealed?
Inheritance agreements: are agreements between heirs permitted or required?
Local procedures: will the authorities recognise a different procedure if foreign law applies?

Step 3: administer the estate

Determine tax liabilities

Assess inheritance and estate tax exposure in each jurisdiction.
Identify applicable reliefs and exemptions.
Determine primary taxing rights and apply any relevant double tax treaties.
File tax returns as required.

Obtain legal authorisation and take administrative steps

Apply for probate or equivalent authority in each jurisdiction.
Consider sequencing of probate applications and whether grants can be re-sealed.
Be mindful of original will requirements – some jurisdictions require submission of the original, which may complicate parallel applications.
Update asset ownership with relevant authorities (eg land registries, corporate registries).

Distribute assets

Identify and locate all beneficiaries under the will or under forced heirship and intestacy rules.
Ensure all debts, taxes, and administration expenses have been dealt with.
Distribute assets in accordance with the will and local laws.
Where assets pass into trust, document and effect transfers to trustees.

Key takeaways

Administering a cross-border estate is a strategic exercise requiring precision, coordination, and foresight. Much like solving a Rubik’s cube, a move in one jurisdiction can impact the administration in another. A holistic approach is essential to ensure alignment across all jurisdictions.

Engaging legal and tax professionals with expertise in international estate planning and administration is critical to navigating the administration of complex cross-border estates. We work with other lawyers and with notaries and tax professionals across the world to help administer international estates efficiently and effectively.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.