Cross-Border Wills Guide
A comprehensive guide to making your will work across borders as a UK expat. Covers EU Succession Regulation, multiple wills strategy, forced heirship rules, digital assets and UK probate for non-residents.
Your estate profile
Will planning checklist
Track your progress on essential will planning steps.
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Will strategy guide
EU Succession Regulation (Brussels IV)
Forced heirship rules by country
🇫🇷 France
Reserved portion: 1 child = 50%, 2 children = 66%, 3+ children = 75%. Spouses may only receive the income of the estate (usufruit) unless given full ownership by election. Brussels IV allows UK citizens to elect UK law to apply.
🇪🇸 Spain
Compulsory portions for children: 2/3 of estate (1/3 strict, 1/3 improvement, 1/3 free). Spouses have a usufruct right. Regional laws (Catalonia, Basque Country etc.) vary. Brussels IV nationality election available for UK nationals.
🇩🇪 Germany
Compulsory share (Pflichtteil): half the statutory entitlement in value. Children, parents and spouses can claim. Brussels IV applies — UK nationals may elect UK law.
🇦🇪 UAE
Sharia law default for Muslims. Non-Muslims may register a will with the DIFC Wills Service Centre or Abu Dhabi Judicial Department. Without registration, UAE law applies to UAE assets, which may not align with your intentions.
🇹🇭 Thailand
Foreigners cannot own land. Condo/leasehold interests can pass by Thai will. Register a Thai will with the Amphoe (district office). UK will has limited effect on Thai assets.
🇦🇺 Australia
Testamentary freedom but courts can order provision for dependants (Family Provision Claims). AU assets generally governed by AU law regardless of UK will. Consider dual wills.