Estate Planning for Expats
Tailored Financial Services for Global Citizens
Estate Planning for Global Families
Estate planning is how you make sure that what you have built passes to the people you choose, with as little friction, delay and cost as possible. When your life and assets cross borders, it becomes considerably more complex, and considerably more important.
Different countries apply different rules to the same estate, and the consequences of leaving it unplanned fall on your family at the hardest possible time. NEBA Private Clients helps internationally mobile families plan with clarity and confidence.
Why are cross-border estates different?
A single will and a simple plan may be enough when your life sits within one country. Once you hold assets in more than one, several complications arise:
- assets are often governed by the rules of the country where they are located (their “situs”), not where you live;
- probate may need to be granted in more than one country, causing delay and cost; and
- a will valid in one jurisdiction may not be effective, or even recognised, in another.
What is forced heirship, and can I avoid it?
Many countries, particularly in Europe, the Middle East and parts of Asia, apply “forced heirship” rules that dictate who must inherit a fixed share of your estate, regardless of what your will says. Expats are frequently caught out by this, discovering too late that local law overrides their intentions. Understanding which rules apply to your assets is essential.
If you own property in the EU, the EU Succession Regulation generally lets you choose, in your will, the law of your nationality to govern your estate. For British nationals this can be a way to avoid local forced heirship rules. It does not apply in Denmark or Ireland, and it does not change how the estate is taxed.
Do I need a will in the UAE?
If you live in the UAE and are not Muslim, registering a will locally, for example with the DIFC Courts Wills Service or the Abu Dhabi Judicial Department, helps ensure your wishes for your UAE assets are recognised. Without one, UAE default rules decide how those assets are divided, and a will made in your home country may not be enough on its own.
What does a cross-border estate plan include?
Depending on your circumstances, an effective cross-border plan may involve:
- coordinated wills covering assets in each relevant jurisdiction;
- trusts or other structures to manage how and when wealth passes;
- alignment with inheritance tax planning so your estate is not eroded unnecessarily; and
- clear, up-to-date beneficiary arrangements.
The right combination depends entirely on your situation, which is why tailored advice matters.
How NEBA Private Clients helps
- We map your estate across every jurisdiction where you hold assets.
- We identify risks such as forced heirship, multiple probate and conflicting wills.
- We coordinate a joined-up plan, drawing on regulated permissions across the UAE, Singapore, Malaysia, South Africa and the UK, including FCA-regulated UK operations through our membership of TEAM plc.
- We keep your plan current as your life and the rules change.
This page is general information, not legal or tax advice.
Frequently asked questions
Do I need more than one will if I have assets in different countries?
Often, yes. A single will may not be effective in every jurisdiction; coordinated wills are frequently recommended, drafted so they do not accidentally revoke one another.
What is forced heirship?
Rules in some countries that require a fixed share of your estate to pass to certain relatives regardless of your will; it can override your intentions if it applies to your assets.
Will my UK will cover my overseas property?
Not necessarily. Overseas assets are often governed by local law where they are situated; this needs checking jurisdiction by jurisdiction.
How does estate planning relate to inheritance tax?
They are closely linked: a good estate plan is structured with inheritance tax in mind so your estate is not eroded unnecessarily.
When should I put an estate plan in place?
As early as possible, and review it whenever you move country, acquire assets abroad, or have a significant change in family circumstances.
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