Estate Planning for International Property Investors: A Complete Guide

Owning a single property in one country is straightforward enough. Owning a portfolio spanning multiple jurisdictions — a buy-to-let in Manchester, an apartment in Dubai, a villa in Marbella — creates an estate planning challenge of an entirely different order.

The fundamental problem is this: property passes under the law of the country where it is situated, not the law of your home country and not necessarily under the terms of your will. In many countries, local forced heirship rules, succession procedures, and tax obligations will apply regardless of your intentions. Without proper planning, your estate could end up in protracted legal proceedings across multiple jurisdictions, with your assets passing to people you did not choose, and a tax bill that could have been substantially reduced.

This guide sets out the key issues every international property investor needs to address.

Important: Succession law varies substantially by country and by individual circumstance. Nothing here constitutes legal advice. You should retain qualified estate planning lawyers in each country where you hold property, as well as a UK solicitor with international estate planning experience.

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Why a Single Will Is Rarely Enough

Many investors assume that a comprehensive UK will is sufficient to govern all their assets worldwide. It is not, for two main reasons.

First, local law applies to local assets. A Spanish court will apply Spanish succession law to your Spanish property. A Thai court will apply Thai law to your Thai condominium. Your UK will may not be recognised, or may be recognised but overridden by local mandatory rules.

Second, formality requirements differ. Some countries require wills to be notarised, registered locally, or drafted in specific forms. A UK will drafted without reference to these requirements may be invalid or difficult to administer in the property country, causing delay and cost for your heirs.

The standard approach for multi-jurisdiction investors is:

1. A UK will covering UK assets and appointing UK executors.
2. A separate local will in each country where you hold property, drafted by a local lawyer, covering only the assets in that country.
3. Each will must be carefully coordinated so they do not inadvertently revoke each other — a common drafting error.

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Forced Heirship: The Rule That Overrides Your Will

Forced heirship is the most significant constraint on international estate planning. In countries with forced heirship rules, a fixed proportion of the estate — known as the "reserved portion" or "legitime" — must pass to protected relatives regardless of what any will says.

Key Markets

Country	Forced Heirship?	Notes
Spain	Yes	Reserved portion varies; children entitled to 2/3 of estate in most cases. Regional variations apply.
Greece	Yes	Children entitled to half the estate (legitime).
Cyprus	Yes	Children and spouse have protected shares.
France	Yes	Children's reserved portion: 50% (one child), 67% (two), 75% (three or more).
UAE	Yes (Sharia default)	DIFC/RAK wills allow non-Muslims to opt out for UAE assets.
Thailand	No strict forced heirship	But intestacy rules apply if no valid will; foreign heirs may face restrictions.
Indonesia (Bali)	Yes (civil law basis)	Inheritance law complex; Islamic inheritance law applies to Muslim estates.
UK	No	"Reasonable financial provision" claims possible but courts have discretion.

Where you own property in a forced heirship country, your estate plan must work within those constraints. This may mean gifting assets during your lifetime, restructuring ownership, or accepting that a portion of the estate will pass to heirs you would not have chosen.

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EU Succession Regulation (Brussels IV) — and Why UK Nationals Are Excluded

Before Brexit, UK nationals resident in EU countries could use the EU Succession Regulation (Brussels IV) to elect that the law of their home country (i.e. UK law) would govern their entire EU estate. This was useful for British nationals in Spain, Greece, or Cyprus who wished to avoid forced heirship rules.

Since Brexit, UK nationals can no longer elect UK law under Brussels IV. UK nationals resident in EU member states are subject to the succession laws of the country where they are resident — which, in Spain, Greece, Cyprus, and France, includes forced heirship rules.

There are still planning options — for example, structuring ownership through a company in some cases, or making gifts during lifetime — but these require professional advice in the relevant country, as the options and their tax consequences differ significantly by jurisdiction.

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UAE: Sharia Succession and DIFC Wills

The UAE presents particular complexity for non-Muslim investors. By default, all assets in the UAE — including Dubai freehold property — are distributed under Sharia law on the death of the owner, regardless of nationality or religion. For non-Muslim investors, this can produce outcomes dramatically at odds with their intentions.

Under Sharia succession, property passes to specified relatives in prescribed proportions. Unmarried partners receive nothing. Non-Muslim heirs may face complications. The process can be slow and require a UAE court order.

DIFC Wills (registered with the Dubai International Financial Centre Wills and Probate Registry) allow non-Muslims to direct the succession of their Dubai, Ras Al Khaimah, and — following recent expansions — other UAE assets under English-law-style principles. A DIFC will can name any beneficiary, appoint guardians for children, and appoint executors, broadly as an English will can.

The RAK Wills Centre covers assets in Ras Al Khaimah specifically. Both registries require the will to be formally registered; they are not simply documents held by a solicitor.

For any non-Muslim investor owning UAE property, a DIFC or RAK will is a practical necessity. Our UAE property guide covers ownership structures in more detail.

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Thailand: Condos, Leaseholds, and Succession

Foreign nationals can inherit a Thai condominium unit, but if the inheritance would cause the total foreign ownership in the building to exceed 49%, the heir has one year to sell the unit. This is not a theoretical risk in popular developments.

Leasehold interests are more complex. Most Thai leasehold agreements do not contain automatic survivorship provisions — the lease may or may not be transferable to heirs depending on its terms. Review the lease agreement carefully before purchase, and consider whether a survivorship clause can be negotiated.

Foreign investors cannot own Thai land outright. Structures such as Thai companies holding land should be reviewed by a Thai lawyer for their succession implications — company shares can be transferred by will, but Thai company law requirements must be met.

See our Thailand property guide for more on ownership structures.

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Indonesia (Bali): PT PMA and Leasehold Succession

In Indonesia, foreign nationals cannot own freehold land (Hak Milik). The main routes are leasehold (Hak Sewa), right to use (Hak Pakai), or ownership through a PT PMA (foreign-owned Indonesian company).

For leasehold, the lease can typically be transferred to foreign heirs within the remaining term. PT PMA company shares can be left by will and transferred to heirs, making the company structure more succession-friendly — though Indonesian corporate formalities must be observed.

Local legal advice from an Indonesian notary (notaris) is essential for estate planning involving Bali property.

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The Practical Estate Planning Checklist

For an investor with property in multiple countries, a sound estate plan requires:

• Local will in each property country, drafted by a qualified local lawyer, limited to assets in that country.
• UK will covering UK assets and confirming the scope of each overseas will to avoid revocation.
• DIFC/RAK will if you own UAE property (non-Muslims).
• Power of attorney in each property country — authorising someone to manage or sell the property if you are incapacitated. Without this, property management can become impossible during a serious illness.
• Asset schedule — a clear, accessible document listing all properties, account numbers, structures, and the location of each will and title deed. Executors and heirs need to find these quickly.
• Review cycle — at minimum every three to five years, and after any major life event: purchase, sale, marriage, divorce, birth of a child, or a change in succession law.
• Life insurance — to fund IHT liabilities without requiring heirs to sell property to meet the tax bill.
• Professional co-ordination — your UK solicitor and overseas lawyers should be aware of each other's work. Inconsistencies between wills can create significant problems.

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Inheritance Tax and Estate Taxes: the Cross-Border Dimension

Estate planning is not only about ensuring assets reach the right people. It is also about managing the tax cost. The UK's inheritance tax rules — including the April 2025 shift to a residence-based system — may mean your overseas property is within scope of 40% UK IHT. Separately, the property country may levy its own succession or inheritance taxes.

Our guide to inheritance tax on overseas property for UK expats covers the UK IHT rules in detail. For the tax implications of transferring property to family members during your lifetime, see transferring overseas property to family members.

Investors considering residency or citizenship programmes — which can affect both domicile and residence status — should also review our residency and citizenship guide.

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How Global Investments Can Help

Estate planning across multiple jurisdictions requires more than a single adviser. It requires a team of co-ordinated specialists — UK estate planning solicitors, local lawyers in each property country, tax advisers, and financial planners — working from a consistent picture of your assets and intentions.

Global Investments has established relationships with qualified estate planning lawyers across all eight of our core markets: the UK, UAE, Thailand, Spain, Bali, Egypt, Greece, and Cyprus. We can co-ordinate the appointment of local specialists, ensure your wills are consistent, and integrate estate planning into your broader wealth management strategy.

To discuss your estate planning needs, contact our team.

This guide is for general information only, as of June 2026. Succession law, forced heirship rules, and inheritance tax legislation vary by country and are subject to change. Individual circumstances differ significantly. Always seek qualified legal advice in each relevant jurisdiction before acting.