With increasing globalisation, many UK residents own property or assets in other countries. International estate planning adds complexity but is essential to ensure your worldwide assets are properly managed.
An English Will only covers assets in England and Wales. If you own property in Scotland, Northern Ireland, or another country, you may need a separate Will for each jurisdiction.
Different countries have different inheritance laws. Many European countries have 'forced heirship' rules, which require a certain portion of the estate to go to specific family members regardless of the Will. Since Brexit, the EU Succession Regulation no longer applies to UK nationals.
Double taxation can be a significant issue. If you own property in another country, you may face inheritance tax in both the UK and that country. The UK has double taxation agreements with some countries, but not all.
It's crucial that your Wills in different jurisdictions don't conflict with each other. Each Will should clearly state that it covers only the assets in that specific jurisdiction, to avoid inadvertently revoking a Will in another country.
In 2026, with many UK residents owning holiday homes in Spain, France, Portugal, and beyond, international estate planning is more relevant than ever.
At Castle Family Legal, we can advise on the UK aspects of international estate planning and work alongside specialist advisors in other jurisdictions. Contact us to discuss your international assets.
