Wills and succession across jurisdictions

5 min · For educational purposes only

A single Indian will may not cover offshore assets cleanly. The professional standard is jurisdiction-specific wills coordinated under a master estate plan.

Different jurisdictions follow different succession regimes — common law (India, US, UK), civil law (most of Europe), and forced-heirship regimes (parts of Middle East). A will valid in India may be probated abroad but with delays and translations that consume years.

The standard solution: a separate jurisdiction-specific will covering each material asset location, drafted by counsel in that jurisdiction, with a master document coordinating them so no clause contradicts another.

Common structural choices

Indian will covering Indian and IFSC assets
US will covering US-situs assets, drafted by a US estate attorney
Foreign trust for asset segregation and managed succession
Insurance wrapper as a private succession instrument

Key takeaways

One will per material jurisdiction.
Coordinate language carefully — contradiction triggers litigation.
Trusts and insurance wrappers are succession tools, not just tax tools.