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Multiple jurisdiction wills can be advisable but only if they are carefully drafted by specialists. The main danger is that a standard revocation clause will accidentally revoke an earlier will for another country. A Brussels IV election in a single UK will is often the simpler alternative for EU property.
If you own assets in more than one country, you may be advised to make separate wills for each country. The logic is that each country's administration will be simpler if there is a local will in the local language that the local court, notary, or registrar can act on directly.
However, multiple wills carry significant risks if not properly drafted. This guide explains the benefits and dangers, the critical importance of limited revocation clauses, the alternatives, and when multiple wills are and are not the right solution.
There are genuine advantages to having separate wills for different countries:
The biggest danger with multiple wills is the standard revocation clause. Most standard wills contain a clause along the lines of: “I hereby revoke all former wills and testamentary documents previously made by me.”
If your UK will contains this clause and you subsequently make a French will, the French will may revoke your UK will. If the French will only deals with French property, you could die intestate (without a valid will) for your UK and other assets.
The solution is to use limited revocation clauses in each will. For example:
These limited revocation clauses must be drafted by a lawyer who understands both the UK and foreign law implications. A mistake here can result in partial intestacy, which may be difficult and expensive to resolve after death.
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For UK citizens with EU property, the EU Succession Regulation 650/2012 (Brussels IV) provides an alternative to multiple wills. By including a formal election of UK law in your UK will, you can direct that UK succession law governs your assets in EU member states — including France, Spain, Italy, Germany, and Portugal.
Advantages of this approach:
Disadvantages:
For more on the Brussels IV election, see our guide on the EU Succession Regulation.
Multiple jurisdiction wills are most advisable when:
Always instruct a specialist who is qualified in both UK law and the relevant foreign law. Do not simply translate a UK will — the legal requirements of different countries vary enormously in terms of execution formalities, witnessing, and content.
If the deceased had multiple wills, the executor must:
For the broader estate administration picture, see our complete UK probate guide, estate administration checklist, and our UK inheritance tax guide. For questions about whether a UK will covers overseas property, see our guide on overseas property in a UK will. For recognition of a foreign grant in the UK, see our guide on how a foreign grant is recognised in the UK. For document authentication, see our guide on apostilling a foreign death certificate. For the EU Succession Regulation, see our EU Succession Regulation guide. For resealing a Commonwealth grant, see our guide on resealing a Commonwealth grant of probate.
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