England & Wales · EU · Gulf · South Asia · USA
Most wills are written as though everything sits in one country and one filing cabinet. Real estates now span a house abroad, an offshore account, a family obligation under another legal system, and a wallet nobody else can open. We draft for the estate you actually have.
Twelve questions. No account, no payment.
Three problems, one practice
Not a template generator and not a crypto gadget. A practice built around the three places modern estates break.
A property in Spain, a pension in the UK, a bank account in Dubai and heirs on three continents. We map which law governs each asset, whether forced heirship bites, whether a Brussels IV election helps, and how many wills you need - then draft them so they don’t cancel each other out.
How cross-border planning works →A farāʾiḍ-compliant distribution that is also a valid English will: the fixed shares calculated properly, the one-third wasiyyah used deliberately, and the 1975 Act risk identified in advance rather than discovered by your family in court.
How Islamic wills work in England →The Property (Digital Assets etc) Act 2025 settled that your tokens are property. It did not settle how anyone reaches them. We handle both halves: the clauses that transmit ownership, and the key architecture that makes ownership mean something.
Digital asset succession →“A thing (including a thing that is digital or electronic in nature) is not prevented from being the object of personal property rights merely because it is neither— (a) a thing in possession, nor (b) a thing in action.” Property (Digital Assets etc) Act 2025 (c. 29), s.1 - legislation.gov.uk. Royal Assent 2 December 2025; in force on the day passed (s.2(2)); extends to England and Wales and Northern Ireland (s.2(1)).
That single sentence resolved years of uncertainty about whether a crypto-token, a tokenised carbon credit or an in-game asset could be owned at all in England and Wales. It matters for estates because property is what passes under a will - and what an executor is obliged to collect.
What the Act deliberately did not do is just as important. It does not define which digital things qualify, it creates no register, and it leaves the boundaries of this new “third category” for the courts to draw case by case. And it says nothing at all about access. An estate can now own a wallet outright and still be permanently locked out of it.
The practical gap. Property status answers who owns it. It does not answer who can reach it. A succession plan that solves only the first half leaves your executors with a legally perfect claim to an inaccessible asset.
How we work
Every asset, its situs, and the law that governs it. Most clients discover at this stage that at least one asset is governed by a law they had not considered.
What happens on death under the current arrangements - including the version where nothing is done. We show you the failure modes before we propose fixes.
The wills, the letters of wishes, the digital-asset schedule and the key-recovery architecture. Drafted as one instrument set, not four unrelated documents.
An annual review, because domicile changes, jurisdictions change their rules, exchanges fail, and heirs are born. A will written once is a will that expires quietly.
| If you are… | The risk we most often find |
|---|---|
| A UK resident with property in the EU | An English will that cannot pass foreign land, and a missed Brussels IV choice-of-law election that would have avoided forced heirship. |
| A Muslim family in the UK | A Shariah distribution written as a wish rather than a disposition, or one that fails formality and drops the estate into intestacy - the opposite of the intended result. |
| Holding crypto, NFTs or tokenised assets | No inventory, no key-recovery plan, and executors who do not know the assets exist. The most common outcome is permanent loss, not dispute. |
| An expatriate or returning non-dom | Domicile assumed rather than analysed, and two wills that unintentionally revoke one another. |
| An executor already dealing with a foreign estate | A grant that needs resealing, or an estate where two jurisdictions each claim primary administration. |
| A will-writer, adviser or probate professional | A file that has gone cross-border or digital and needs specialist support behind the scenes. We work on referral and stay off your client relationship. |
Often, yes. A single English will can in principle deal with worldwide assets, but foreign land is governed by the law where it sits, and several countries will not accept an English will without translation, legalisation and a local process - some not at all where forced heirship applies. The usual answer is a primary English will plus a carefully limited local will for each relevant jurisdiction, drafted so that neither revokes the other. That last point is where most DIY multi-will arrangements fail.
Yes. The Property (Digital Assets etc) Act 2025 confirms that a digital thing is not prevented from being the object of personal property rights merely because it is neither a thing in possession nor a thing in action. So a crypto-token can be owned, and can pass under a will. The Act does not, however, give anyone access to your keys - that remains a practical problem you have to solve separately.
Yes. English law allows almost unlimited testamentary freedom, so a testator may direct that their estate be distributed according to farāʾiḍ. The will must satisfy the Wills Act 1837 formalities, should be drafted so it does not fail into intestacy, and should be reviewed against the Inheritance (Provision for Family and Dependants) Act 1975, under which certain people can apply to the court for provision regardless of what the will says.
No. iProbate provides will-writing, estate planning and estate administration. We do not carry out reserved legal activities under the Legal Services Act 2007. Where a matter needs a regulated practitioner - contentious probate, litigation, advocacy - we say so and refer you to one.