Expat Estate Planning: What Happens When Your Assets Sit in More Than One Country

You moved for work, and your money followed you. A salary account where you live now. A house and a pension back home. A brokerage account opened in a third country because the platform happened to accept your residency. Nothing about that is unusual — the UN counted 281 million people living outside their country of origin in 2020, up from 173 million in 2000 (UN DESA). And none of it is a problem while you are alive to explain it.

The problem is that each of those countries treats your death as a separate event, under its own law, in its own language, on its own timetable — and none of them will tell the others. This is the part most expat estate planning advice skips. The hard question is not "should I write a will" — that has its own answer. The hard question is what your family is actually required to do, country by country, before a single account releases a single unit of currency.

The short version

If you hold assets in more than one country, your estate is settled once per country — each under its own succession law, its own probate process and its own tax authority. A grant of probate from one country does not automatically operate in another, and a will valid where you live may not reach the house back home. The single most useful document you can leave is not the will. It is a country-by-country map of what exists and where.

Why does living abroad make an estate so much harder to settle?

An estate is not settled once. It is settled once per jurisdiction, and each jurisdiction only has power over what sits inside its own borders. Your executor cannot present one death certificate and one court order everywhere; they must satisfy each country separately, in that country's language, with that country's documents.

Three multipliers stack on top of each other:

• Law. Different countries apply different rules to decide *who inherits*. The answer can genuinely differ depending on which country is asking.
• Process. Probate, a succession certificate, or the local equivalent must usually be obtained in each country where assets sit. One grant does not travel.
• Tax. More than one country can have a legitimate claim on the same estate — one because you lived there, another because the asset is physically there. The OECD found that 24 of its 38 member countries levy an inheritance or estate tax (Inheritance Taxation in OECD Countries, 2021).

And underneath all three sits the quiet failure that causes the most damage: nobody knows the accounts exist. A court order is useless against an account your family has never heard of, at an institution in a country they have never visited.

Which country's law decides who inherits what?

There is no single answer, and that is the point. Most systems split the estate in two: immovable property — land and buildings — is governed by the law of the country where it physically sits, while movable property such as bank accounts and securities usually follows the law of your domicile or habitual residence at death. So one estate can be governed by three laws at once.

Two further wrinkles matter enormously for expats.

Forced heirship. Much of civil-law Europe, the Middle East and parts of Asia reserves fixed shares of an estate for particular relatives. In those systems a will is not a blank cheque — the reserved share applies whatever the will says, and a local court will simply disregard the part that conflicts.

You may be able to choose. Within the EU, Regulation 650/2012 (known as Brussels IV) makes the law of your habitual residence at death the default for your whole estate — but Article 22 lets you expressly choose the law of a country whose nationality you hold instead, and that choice governs the entire succession (EUR-Lex). It is a genuinely powerful tool for an EU-resident foreign national, and it only works if you make the election in writing while you are alive. Note that Ireland and Denmark are not bound by the Regulation and apply their own rules, and the UK never applied it.

The UAE offers a comparable election. Under Federal Decree-Law No. 41 of 2022 on Civil Personal Status, the civil regime applies to non-Muslims resident in the country for matters including inheritance and wills, unless a party adheres to the application of their own national law — and non-Muslim expats can register a will with the DIFC Wills Service Centre to have their estate distributed according to their wishes rather than the default rules. Again: an election, made in advance, in writing.

Do I have to go through probate in every country?

Usually yes — in every country where you hold assets that need a court's authority to release. A grant of probate is an order of one country's court, and it does not automatically bind a bank or land registry in another. Where recognition exists at all, it is a procedure, not an automatic effect.

The clearest illustration is the mechanism built specifically to soften the problem: under the UK's Colonial Probates Act 1892, a grant issued in a British possession to which the Act has been extended "may, on being produced to, and a copy thereof deposited with, a court of probate in the United Kingdom, be sealed with the seal of that court" (legislation.gov.uk). That is *resealing* — a second, lighter application, still an application. And it only covers a defined list of countries. Everywhere outside such an arrangement, your executor starts again from scratch. In the United States, foreign-domiciled decedents with US property typically face an ancillary probate — a separate proceeding in the state where the property sits.

The practical consequence is timing, and timing is what hurts a family. Each jurisdiction's clock starts when *its* paperwork is filed — not when you died. If your executor spends four months obtaining authority where you lived and only then discovers an account in a third country, that third country's process starts in month five. Sequential, not parallel. This is why cross-border estates are routinely described in years rather than months, and why the real goal of expat planning is not tax efficiency — it is shortening the discovery phase to zero.

Which countries can tax the same estate?

More than one, and often for different reasons: one country taxes because you were resident there, another because the asset is physically there. Three worked examples show how fast this catches ordinary people who never considered themselves wealthy.

The United States taxes foreigners on US assets from $60,000. If you are neither a US citizen nor domiciled there, your estate must file Form 706-NA once the date-of-death value of your US-situated assets exceeds a filing threshold of just $60,000 — against a top estate-tax rate of 40% (IRS). And "US-situated" is broader than it sounds: US real estate counts, and so does stock in a US-incorporated company, because the IRS treats "stock of corporations organized in or under U.S. law" as property located in the United States no matter where the certificates or the brokerage account sit. A modest holding of US shares bought through a broker in Dubai or Tokyo can cross that line.

Japan reaches worldwide assets after ten years. Japanese inheritance tax runs to a top rate of 55%, with a basic exemption of ¥30 million plus ¥6 million per statutory heir. A foreign national is treated as a "temporary resident" only while they have had an address in Japan for ten years or less within the last fifteen; beyond that threshold, worldwide assets come into scope (National Tax Agency). Long-stay expats in Japan cross this line without any change in their circumstances — simply by staying.

The UK now looks at residence, not domicile. For deaths after 5 April 2025 the UK moved to a residence-based inheritance tax regime: HMRC "will treat you as being based abroad if you have lived in the UK for less than 10 years in the last 20." Above that, your worldwide estate is in scope, against a £325,000 nil-rate band and a 40% standard rate (GOV.UK). Britons who left recently, and long-term arrivals who never thought of themselves as British, are both affected.

None of this means your family will be taxed twice on the same asset — estate tax treaties and unilateral credits exist precisely to relieve that. But relief has to be claimed, in a filing, within a deadline, by someone who knows the asset exists. An unclaimed credit is an unpaid tax bill.

What does your family need to know that no registry can tell them?

Here is the asymmetry at the heart of all of this. Every country has a process for *proving* a claim. Almost none has a process for *discovering* one.

There is no international register of a person's bank accounts. No court will hand your spouse a list. National search services exist in some countries and are worth using, but they are partial, slow, and cannot find what was never reported to them. An account in a country your family does not know you held money in will simply stay dormant, and in most jurisdictions eventually pass to the state as unclaimed property. We wrote a full guide to searching for unclaimed money left by a relative, and its honest conclusion is that searching is a poor substitute for being told.

So the document that does more work than any will, in any country, is unglamorous: a country-by-country inventory of what exists and where. Not the passwords. Not the money. The *map*.

How do you build a country-by-country asset map?

Work country by country rather than account by account — it is the only ordering that matches how the process will actually run.

1. List every country you have a financial footprint in. Include the ones you left. Old accounts, a dormant pension from a first job, a utility deposit, a brokerage account you stopped funding. Footprint, not intention.
2. Under each country, list every asset and every debt. Institution, country, account type, roughly what it holds, and the identifier your family would be asked for. Debts belong here too — in several systems accepting an inheritance means accepting the liabilities with it, and a family cannot weigh that choice against debts it has not seen.
3. Note who has authority, per country. Which will covers this? Is there a named beneficiary on the policy or the pension — because a valid nomination usually pays out outside probate, and is the fastest money your family will see.
4. Write down the local step, in one line each. "This bank requires a succession certificate from the local court." One sentence, from you, saves your executor a month of discovery in a language they do not read.
5. Say where the originals are. Which drawer, which country, which safe. A will nobody can find has the legal force of a will that was never written.
6. Add the human layer. Who to contact in each country, which relative already knows, which adviser holds the file.
7. Review it when your footprint changes — a move, a new job, a closed account, a new platform. An out-of-date map is worse than none, because it will be trusted.

The test is simple, and you can run it tonight: *if I were gone tomorrow, could the person I trust most name every country my money sits in?* If the answer is no, that is the gap — and no will, in any jurisdiction, closes it.

A will decides who receives. The map decides whether they ever find it.

Where WiseEnding fits

WiseEnding is built for exactly this shape of life. My World holds the country-by-country map — accounts, property, debts, receivables, crypto and gold, each recorded with where it lives and what your family would need to do about it. The Family Vault is zero-knowledge encrypted, so your instructions, letters and document locations are readable by you and by the people you name, and by nobody else — not even us. And Legacy Heartbeat, our dead man's switch, makes sure that if you ever cannot speak for yourself, the map reaches them anyway.

If you live in one country and your money lives in several, the map is the more urgent of the two.