Many families we advise own a flat in London, an apartment in Cairo and accounts in both. When someone dies, each country applies its own rules to the property inside its borders, and the answers do not always match.
1. Which law applies to what
As a rule, land and buildings follow the law of the country where they are located. Bank accounts and other movable assets may follow different rules depending on nationality and residence.
2. Why a will in one country may not be enough
A will that works perfectly in England may not be recognised in Egypt, and the other way round. Families with assets in both usually need two coordinated wills, or one will drafted to work in each country.
Key point
The cheapest time to solve a cross-border inheritance problem is before it happens.
3. Dividing the estate by agreement
Where heirs agree, an estate can often be divided without going to court. A clear written summary of what each person inherits under each country’s rules makes agreement far more likely.
“Everyone got the same explanation at the same time. That is what stopped the arguments.”
4. When to take advice
Take advice early if there are heirs in different countries, a family business, or property bought in one person’s name with family money.
