One family, three countries, and a will that only works in one of them

A family I think about often, with the details changed, lived like this. The parents in Dubai. A business in Nairobi. A flat in London where the daughter lived. A will, drawn up carefully, in one of those places.

When the father died, the will did what it was supposed to do in the country where it was written. In the second country it was accepted after a year of correspondence. In the third it was treated as if it did not exist, and the law there decided who got the flat.

Nobody had done anything wrong. They had done one thing, well, in one place.

Why one will is not enough

Every country has its own rules about what happens to what you own when you die. Some follow the will. Some follow fixed shares set by law, whatever the will says. Some follow religious law. Some treat property differently from money. And every one of them has its own idea about which of the others it will listen to.

If your family lives in one country and owns things in one country, none of this touches you. Most of the families I work with are not like that. They have a home in one place, a business in another, children studying in a third, and a grandmother's house in a fourth that nobody has quite dealt with.

What actually works

The plain answer is that the paperwork has to match the map. In practice that means a few things.

A will for each place, or one will that has been checked in each place. Separate wills are more common. They have to be written so that the second does not accidentally cancel the first, which happens more than you would think.

Knowing which assets sit where. This sounds obvious. It is the step most often skipped. Shares in a company registered in one country are in that country, even if the company's office is somewhere else and its bank is somewhere else again.

One structure for the things that move. For families with holdings in several countries, this is often where a trust or a holding company earns its keep: the assets are gathered in one place with one set of rules, and the wills only have to deal with what is left.

A list. One page, kept current, that says what exists, where it is, and who to call. I have watched families spend a year reconstructing this from bank statements. The list takes an afternoon.

The conversation to have this year

You do not have to solve all of this at once. You do have to know the shape of it. If you can answer, for each thing you own, which country's rules would apply to it tomorrow, you are ahead of most people. If you cannot, that is the conversation to have this year, not next.