Wills and estate planning across two countries — did you get this sorted before or after moving?

Got a specialist cross-border advisor rather than a general solicitor. Worth the extra cost purely for the peace of mind alone.

Still putting this off too, this thread is a good nudge.

Ended up needing two separate wills that reference each other carefully — apparently a fairly common approach, though I’m obviously not a lawyer myself.

Did anyone find their home-country will already covered assets abroad, or is that basically never the case in practice?

Chris, to your question about whether a home-country will covers assets abroad: in our case it technically did, and it would still have been a mess. Our solicitor in England told us the will was valid, but the notary in Portugal explained, very patiently, that getting a foreign will recognised and acted on here involves translations, certifications and a lot of time, all while the family is grieving.

So we did what Helga described: a separate Portuguese will for the house here, drafted by a local notary, and our English will for everything in the UK, each one carefully referring to the other so that neither accidentally cancels the other. The notary also explained how the local inheritance rules would apply to us, which was not what I'd assumed, and that alone was worth the appointment.

It cost a fraction of what I'd feared, took two appointments, and the main feeling afterwards was relief. Our children know where both documents are. If you're putting it off like we were, the relief is worth more than the fee.

Our wills are on this autumn's list because of this thread.

Ben's experience matches the general advice: a will that is valid in one country can still be slow and complicated to use in another, and which country's inheritance rules apply depends on your nationality, your residence and any choice you make in the will itself. The Estate section of each country guide covers the basics, for example the Estate section for Spain, but this is a clear case for a qualified notary or cross-border lawyer, as several people here have said.

Reading this before our move has changed our plan. We were going to "sort it out once we're settled", and I can see now that settled never quite arrives. We've booked an appointment with a lawyer in Sweden who works with Spanish colleagues, so both wills are written together rather than months apart.

Thank you, Ben, that answers my question completely and a little alarmingly.