A single will
Potential benefits
- A simpler set of documents.
- One place to see the overall intention.
Potential considerations
- Recognition abroad.
- Local law.
- Probate that may have to be repeated.
Wealth
Understand how wills, ownership, beneficiaries, property and succession can interact across multiple jurisdictions.
A document that works in one country may not produce the same result somewhere else.

Estate planning is the process of deciding how assets, responsibilities and decision-making authority should be handled during life, on incapacity and after death.
For internationally mobile families, the challenge is that property, investments, pensions, companies, beneficiaries and legal documents may all sit in different jurisdictions. A plan that works in one country may not automatically produce the same result elsewhere.
This page stays with ownership, family planning and how the documents fit together. Tax residence, inheritance concepts and how a will is recognised are covered on cross-border estate planning.
The starting point is not simply “Do I have a will?” It is whether the ownership, beneficiary instructions and legal documents across your financial life still work together.
The big picture
Estate planning is not only about what happens after death. It is about who can act, who receives what, and how ownership works when circumstances change.
Cross-border families often need to coordinate wills, property ownership, beneficiary nominations, company interests and incapacity planning across more than one legal system.
The basics
Documents setting out how certain assets should be dealt with after death, subject to local law.
How assets are legally owned can affect whether they pass through an estate or by another mechanism.
Pensions, insurance policies, trusts and some accounts may rely on separate beneficiary instructions.
Powers of attorney or equivalent arrangements can determine who may act if you cannot make decisions yourself.
Business interests, family companies and long-term ownership often need separate planning.
Executors, trustees and other representatives may need authority to identify, value and distribute assets.
Cross-border succession
Where you live may influence which laws or tax rules apply.
Some jurisdictions may connect succession rules to nationality.
Real estate may be governed by local law.
Some systems use broader connecting factors beyond residence.
Heirs may live in different countries and face different reporting or tax obligations.
A document valid in one country may need local review before being relied upon elsewhere.
Different legal systems use different connecting concepts. Specialist legal advice may be required to determine which laws apply.
Wills
A will’s usefulness abroad can depend on local validity, whether it deals with foreign assets, how it sits alongside another will, the risk that one document revokes another, who the executors are, the language, local formalities, and how probate or administration works in each place.
Potential benefits
Potential considerations
Potential benefits
Potential considerations
This is not a recommendation to use one or multiple wills. The appropriate structure depends on the jurisdictions and assets involved.
Ownership
Ownership can be sole, joint, through a nominee or custodian, through a trust, or through a company. Pensions and insurance policies may name their own beneficiaries. Each of those can send an asset down a different path.
01
The house, account, policy or shares.
02
The name on the title, register or account.
03
Will, joint ownership, trust terms, or a beneficiary nomination.
Some assets may pass under a will. Others may pass through joint ownership, trust terms, pension nominations or insurance beneficiary designations.
Property
Real estate may be subject to the rules of the place where it stands. Title structure matters, and so does the form of any joint ownership. A lender may have its own interest. Local probate may be required. Some jurisdictions have forced-heirship or reserved-share concepts. Tax may arise in more than one country. None of those outcomes is decided on this page.

Incapacity
Incapacity planning is about who may make decisions while you are alive but unable to act: financial decisions, healthcare decisions, bank access, property, and business interests. A local equivalent may exist, and family authority is not the same as a document an institution will accept.
A power of attorney created in one country may not automatically be accepted by institutions in another.
Who can deal with accounts and investments.
Who can be involved in care decisions, where a local document exists for that.
Who can act for a company or a founder.
Who can deal with a home in each country where one is owned.
Beneficiary assets
Pension nominations, death benefits and insurance beneficiary designations can direct money separately from a will. Trustees may have discretion. A nomination made years ago can still be the one on file, including one that names a former spouse or omits a dependant.
A will and a beneficiary nomination may govern different assets.
Structures
At a high level, a structure separates legal ownership from the person who may benefit. Trustees, beneficiaries, and sometimes a protector or other governance role, sit around the assets. Company shares raise a further question of who succeeds to control. Reporting, tax and legal treatment can all change when a border is crossed.
This page does not recommend a trust or a holding company.
Structures that work well in one jurisdiction may be treated very differently in another.
Business succession
Shareholder agreements, voting control and economic ownership can point in different directions. Key-person risk, whether the family continues or the business is sold, who sits on the board, and whether heirs would have liquidity are all part of the conversation. Tax and legal advice need to be coordinated. Nothing here chooses an outcome.
The person who currently owns and often controls the business.
Who holds the shares, and in what proportions.
Who can vote, appoint directors, or bind the company.
A successor, a sale, or continued family ownership. These are different outcomes.
Administration
An executor or personal representative may need to obtain probate or a local equivalent, collect assets, deal with liabilities, see to tax filings and distribute what remains. Foreign recognition is a separate step. More than one jurisdiction can mean more than one process. The order below is a way of seeing the work. It is not a procedure for any particular country.
Who is named to act, and whether they can do so in practice.
Finding assets, documents and liabilities, including those abroad.
Debts, expenses and any tax filings the relevant countries require.
Passing what remains, under the documents and the law that applies.
Family
Parents often want to record guardian wishes, who would have day-to-day care, how residence and schooling would work, whether a trust holds money for a child, who can access funds, and at what point a child inherits outright. Family coordination matters as much as the document.
Guardianship law is jurisdiction-specific. Wishes in a will may not automatically determine the legal outcome.
Digital estate
The list can include online banking, investment accounts, email, cloud storage, subscriptions, crypto assets, domain names, social accounts, password managers and the devices themselves. Crypto assets raise their own legal and tax questions. This page does not answer them.
Records
A private list, kept with your advisers or in a place your family can reach. This page does not store what you write down.
Where held. Where is the original kept?
Country. Which country was it made in?
Who controls it. Who can locate it?
Last reviewed. When was it last read?
Where held. Where is each original?
Country. Which country was it made for?
Who controls it. Who is appointed?
Last reviewed. When was it last checked?
Where held. Who holds the title documents?
Country. Where is the property?
Who controls it. Whose name is on the title?
Last reviewed. When was ownership last confirmed?
Where held. Where are the registers kept?
Country. Where is the company formed?
Who controls it. Who are the directors?
Last reviewed. When were filings last checked?
Where held. Who holds the signed copy?
Country. Which law is named in it?
Who controls it. Who must consent to a transfer?
Last reviewed. When was it last read?
Where held. Which provider holds the form?
Country. Where is the scheme administered?
Who controls it. Who is named?
Last reviewed. When was it last updated?
Where held. Where is the policy?
Country. Where is the insurer established?
Who controls it. Who is the beneficiary?
Last reviewed. When was it last confirmed?
Where held. Who holds the deed?
Country. Which law governs the trust?
Who controls it. Who are the trustees?
Last reviewed. When was it last reviewed?
Where held. Which institution?
Country. Where is the account booked?
Who controls it. Who is the account holder?
Last reviewed. When were the details last checked?
Where held. Which provider?
Country. Where is the account booked?
Who controls it. Who is the legal owner?
Last reviewed. When was the statement last filed?
Where held. Where are the instructions stored?
Country. Which providers are involved?
Who controls it. Who should be told?
Last reviewed. When was the list last updated?
Due diligence
Ask a lawyer qualified in the places that may be relevant. Residence, nationality, domicile and the location of assets can all be connecting factors. This page does not decide which law applies.
Ask whether the will was intended to deal with assets outside its home country, and whether those countries will recognise it. A broad clause is not the same as local acceptance.
Sometimes families use one will, sometimes more than one. Neither is universally better. The answer depends on the assets and the jurisdictions, and it is a drafting question for a specialist.
A later will can revoke an earlier one, including a will made in another country, if that is what the words do. Ask a lawyer to read the documents together.
Ask which country’s succession rules may apply to that property, and whether a local grant or local formalities are needed. This page does not describe a particular country’s property law.
Some legal systems reserve a share of an estate for certain relatives. Whether that applies to you, and to which assets, is a question of local law. This page does not set out any country’s reserved shares.
Joint ownership can pass outside a will, or it can pass through the estate, depending on the form of ownership and the local rules. Ask how your particular title is held.
Pension death benefits often follow scheme rules and a nomination, which may sit apart from the will. Ask the scheme, and coordinate that answer with your lawyer.
Proceeds may be paid to a named beneficiary rather than into the estate. Ask the insurer who is currently named, and whether the policy gives anyone discretion.
A document made in one country may not be accepted by a bank, a land registry or a hospital in another. Ask which documents each relevant country and institution will act on.
Ask the institutions that would need to rely on them, and a lawyer in the destination. Acceptance is not automatic.
The useful questions are whether the person is willing, whether they can act in each country involved, and whether a local representative would still be needed.
Authority in one country does not automatically extend to another. Ask what each place requires before someone can collect assets there.
Shares may pass under a will, a shareholder agreement, or both. Ask which document controls a transfer, and whether other shareholders have rights that come first.
Ask whether death, incapacity or a sale is actually covered, and whether the agreement matches the will. This page does not say that an update is required.
A trust that is familiar in one system may be taxed or even disregarded in another. Ask lawyers and tax advisers in each relevant place. This page does not recommend a trust.
A later move can change which documents are recognised and which tax or succession rules are in view. Ask what should be reviewed if residence changes again.
Inheritance, estate and transfer taxes depend on the countries and the assets. Ask a qualified tax adviser. This page does not state rates or thresholds.
They need to know where originals are, who is appointed, and how to contact the advisers. They do not need passwords stored in an ordinary email.
Review after a move, a marriage, a divorce, a birth, a death, or a major change in assets or business ownership. There is no single interval that fits every family.
Watch for
A potential issue does not automatically mean the plan is invalid. It is a reason to review it with qualified professionals.
Common situations
Situations that raise harder questions. They are not legal advice.
01
Questions about the wills, the law that may apply to each property, probate, and whether tax can arise in more than one place.
02
Succession of ownership and of voting control, what the shareholder agreement already says, and how the family would be involved.
03
Property, pensions, beneficiary nominations, and whether the person named as executor can actually act.
04
Who is named, guardianship, how an estate would be administered, and how the family stays coordinated.
05
Two ownership mechanisms, who controls each, and what has to be reported. The trust is not a substitute for reading the will.
06
Whether the existing will, powers of attorney and beneficiary forms still fit the new residence.
Before relocation
After relocation
Simplicity
Cross-border planning can become complicated quickly. More entities, trusts or documents do not automatically produce a better outcome.
Professional support
Compare estate planning providers
Estate planning across borders is about coordinating ownership, legal documents, beneficiaries, fiduciaries and succession across different legal systems.
Compare international private-client, fiduciary and estate-planning providers by wills and executorship capability, trust and foundation services, cross-border estate support, family governance, succession planning and legal/tax coordination.
A provider that is strong in fiduciary implementation may not be the same provider you would use for legal drafting, tax advice or family governance.
Start with the planning need
What to compare
01
Wills, will trusts and executorship capability.
02
Trusts, foundations and professional trustees.
03
Can the provider coordinate more than one jurisdiction?
04
Can they administer estates, or only plan them?
05
Do they coordinate specialist lawyers and tax advisers?
06
Can they support decision-making between generations?
07
Can they help transition wealth or a family business?
08
Can they support charitable or legacy structures?
6 providers listed for comparison.
Private wealth, fiduciary and family office provider
Private wealth and fiduciary services covering estate planning, succession, trustee work and family office support.
Services differ by office and legal entity. Jurisdiction-specific legal and tax advice must be confirmed.
International private client, fiduciary and corporate services provider
Private-client fiduciary services covering estate planning, trusts, foundations and family wealth continuity.
Private-client structures are jurisdiction specific and may require separate legal or tax advice.

International corporate, trust and private-client services group
Corporate, trust and private-client services covering estate and succession planning, trusts and foundations.
Licensed trust and corporate-service activities vary by jurisdiction. Confirm the delivering entity and its regulatory permissions.
International family office, legal, tax and fiduciary group
An integrated family office combining wills, trusts, succession, cross-border tax, family governance and fiduciary coordination.
Services are delivered through different Stonehage Fleming legal entities. Regulatory scope must be checked for the entity that would act.
Independent global fiduciary and corporate services provider
An independent fiduciary provider whose core work is trusts, foundations and cross-border family wealth structures.
Trust and foundation services are regulated and jurisdiction-specific. Tax and legal advice usually sits with external advisers.
Global private wealth, trust and fiduciary provider
Private wealth, trust and fiduciary services for internationally mobile families, including trusts, foundations and selected estate administration.
Trust, estate, legal and tax services vary by jurisdiction and regulated entity. Legal advice may be delivered by a separate regulated law firm.
Short published facts only. These labels describe the provider’s own materials. They are not ratings.
A fiduciary provider, a family office and a professional trustee do not do the same job.
| Provider | Provider type | Best aligned with | Trusts / foundations | Cross-border estates | Wills / executorship | Family governance | Estate administration | View |
|---|---|---|---|---|---|---|---|---|
| Private wealth fiduciary | HNW families · entrepreneurs · family offices | Strong | Strong | Available | Strong | Available | View | |
| Private client fiduciary | HNW families · family businesses · advisers | Core | Strong | Varies by jurisdiction | Strong | Jurisdiction dependent | View | |
![]() | Trust and private client | International families · entrepreneurs · HNW individuals | Strong | Strong | Varies by jurisdiction | Strong | Jurisdiction dependent | View |
Stonehage Fleming Stonehage Fleming | Family office group | UHNW/HNW families · family businesses | Strong | Exceptional | Available | Exceptional | Jurisdiction dependent | View |
| Independent fiduciary | International families · family offices · advisers | Core | Exceptional | Not universal | Strong | Not universal | View | |
| Private wealth fiduciary | HNW/UHNW families · entrepreneurs · family offices | Core | Strong | Selected jurisdictions | Strong | Selected jurisdictions | View |
| Provider | Best aligned with | Trusts / foundations | Cross-border estates | Wills / executorship | Estate administration | View |
|---|---|---|---|---|---|---|
| HNW families · entrepreneurs · family offices | Strong | Strong | Available | Available | View | |
| HNW families · family businesses · advisers | Core | Strong | Varies by jurisdiction | Jurisdiction dependent | View | |
![]() | International families · entrepreneurs · HNW individuals | Strong | Strong | Varies by jurisdiction | Jurisdiction dependent | View |
Stonehage Fleming Stonehage Fleming | UHNW/HNW families · family businesses | Strong | Exceptional | Available | Jurisdiction dependent | View |
| International families · family offices · advisers | Core | Exceptional | Not universal | Not universal | View | |
| HNW/UHNW families · entrepreneurs · family offices | Core | Strong | Selected jurisdictions | Selected jurisdictions | View |
Implements and administers trusts, foundations and estate structures. In this comparison: ZEDRA, Equiom and Hawksford.
Combines governance, legal, tax and fiduciary coordination. In this comparison: Stonehage Fleming.
Acts as professional trustee and administrator. In this comparison: Trident Trust, Sovereign Group and Hawksford.
No provider in this comparison is listed only as an estate or succession coordinator. Confirm whether you need legal drafting, fiduciary implementation, or both.
The right provider depends on whether you need legal drafting, fiduciary implementation, estate administration, family governance — or all four.
Common scenarios
WiT Access provides general information and comparison resources. Estate planning, wills, trusts, inheritance, probate and succession rules vary by jurisdiction and personal circumstances. Nothing on this page constitutes legal, tax, financial or investment advice.
WiT Access does not determine whether a particular will, trust, foundation or succession structure is legally effective or tax appropriate.
Where several jurisdictions are involved, coordinated advice from appropriately qualified legal, tax and fiduciary professionals may be required.
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WiT Access provides general information and comparison resources. Nothing on this page constitutes legal, tax, financial or estate-planning advice. Succession, probate, inheritance, ownership and tax rules vary by jurisdiction and individual circumstances. Consider obtaining advice from appropriately qualified legal and tax professionals.