Cross-border estates.

Reconciling forced heirship and the rules of more than one jurisdiction.

What it is

An estate across borders.

An estate with assets or heirs in more than one country answers to more than one set of rules — and those rules can conflict. Some jurisdictions impose forced heirship that overrides a will; others tax an estate on a different basis entirely. Left unplanned, the result can be a charge in two places and an estate that does not pass as intended.

We map how each relevant jurisdiction treats your estate, plan the structures and instruments that reconcile them, and work with local advisers so that your wishes hold across borders rather than only at home.

How we advise

Conflicting rules

Identifying where the laws of different countries pull against each other.

Forced heirship

Planning around regimes that override testamentary freedom, where the law allows.

Wills and structures

Using wills and structures together so an estate passes as intended.

Local coordination

Working with advisers in each jurisdiction so nothing is missed.

Important information

The basis on which we advise.

This page is general in nature and does not constitute tax, legal or financial advice. Advice is given only under a formal engagement, on the basis of your specific circumstances.

ORA Black advises on the design, selection and coordination of structures; it does not act as trustee, foundation council member or administrator, and does not hold client assets. Fiduciary, formation and administration services are provided by appropriately licensed and regulated providers. Where regulated financial services are required, these are provided through ORA Black’s partnership with NEBA Private Clients.

Discuss your position in confidence.

Speak with a partner