If you own assets in other countries then it is of vital importance that you plan carefully to ensure that all your assets will pass as you intend them to on your death. Each country has their own inheritance laws, as well as their own tax rules, and they can be very different. Hepburn Delaney’s specialist international estate planning solicitors can support you in creating a plan tailored to your particular assets.
International Wills
If you hold assets in more than one country it is advisable to have a Will in each separate jurisdiction. Whilst it is possible to cover assets abroad in a UK Will, there is not always a guarantee that the UK Will shall be considered valid in the other country. It may therefore be the case that the assets in the other jurisdiction will not actually pass as you have specified in your UK Will. Many European countries, for example, operate a system of forced heirship where certain relatives must inherit a set proportion of the estate.
If you make more than one Will it is also essential that they are properly drafted to ensure that one Will does not revoke another.
Our specialist international estate planning solicitors can work with you to ensure you have the right documents in place and we can liaise with lawyers in the other countries on your behalf to arrange separate Wills for you.
International Estate Administration
If someone has died leaving assets in various countries it can be quite a complex process to deal with their estate. We will need to consider whether there are Wills in each jurisdiction and how each of them operates. Sometimes it can be possible to apply for probate in one country first and then have that Grant re-sealed in the courts of the other countries. In other cases, depending on the countries involved, a separate probate process may need to be undertaken in each country.
Careful consideration also needs to be given to taxation and what taxes need to be paid in each country. In certain circumstances UK tax is payable on a person’s worldwide assets so assets in the other countries would be included. Some countries have double taxation treaties with the UK so that if you have to pay tax in both countries you can obtain a credit back so that you are not taxed twice on the same property.
Get in touch with our international estate planning solicitors
Our specialist international estate planning solicitors have vast experience in dealing with estates comprising of assets abroad and can coordinate lawyers in each jurisdiction, taking the complexity away from you.
To contact our Inheritance Team, please call us on 01442 218090 or send an email to info@hepburndelaney.co.uk today.
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“From the very first contact with Sumaiya, I felt confident she was the right person to help us prepare our wills. At our first meeting she explained our options clearly and professionally answering all our questions and providing all the information we needed to make a decision on the best way to proceed. Subsequent communication was clear and timely, and she helped make the whole process very easy for us. We would have no hesitation in contacting Sumaiya for any future matters or recommending her to friends or family”
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