Grant applications
Probate where there is a will, letters of administration where there is not, and the evidence a registry will want when the will is foreign, unusual in form, or its original cannot be produced.
Service
Administering an estate that doesn’t stay in one country
Grants, resealing, ancillary administration and two sets of tax authorities - sequenced so the steps that depend on each other happen in the right order.
Short answer
Administering a cross-border estate means obtaining authority in each place that requires it, in the right sequence. In England and Wales that is a grant of representation; for a grant from a listed Commonwealth jurisdiction, resealing under the Colonial Probates Act 1892 may be available instead. Estates elsewhere - the US, the EU, the Gulf - generally need a separate local process, and a fresh English grant for the English assets.
What we do for personal representatives
Resealing foreign grants
Assessing whether the issuing jurisdiction is one to which the Colonial Probates Act 1892 has been applied, and running the resealing where it is - usually far faster and cheaper than a fresh application.
Ancillary administration
Coordinating with local lawyers and notaries abroad so that each jurisdiction's steps happen in an order that works, rather than three professionals each waiting on the others.
Digital asset recovery
Identifying holdings, preparing bereavement packs for exchanges and custodians, and dealing with platforms whose processes were designed for anything but this.
Where cross-border estates lose time
| Sticking point | What it costs, and how it is avoided |
|---|---|
| Sequencing | An ancillary grant that needed the primary grant first, applied for in the wrong order. Months. Avoided by mapping dependencies before any application is filed. |
| Contested domicile | Two revenue authorities each treating the worldwide estate as theirs. Resolve domicile early, with evidence, rather than after both assessments arrive. |
| Legalisation | Documents rejected for want of an apostille or a certified translation. Cheap to get right first time, slow to fix afterwards. |
| Assets nobody knew about | Discovered after distribution, requiring the administration to be reopened. This is what a lifetime inventory prevents. |
| Currency and volatility | Crypto and foreign-currency assets valued at death, realised months later at a different figure - with tax consequences that need to be planned for, not discovered. |
Contentious matters. If an estate is in dispute - a challenge to the will, a 1975 Act claim, a removal application - that is contentious probate, and it is a reserved legal activity we do not carry out. We will say so immediately and refer you to a regulated practitioner rather than letting the matter drift.
Common questions
How long does probate take in England and Wales?
For a straightforward estate, a grant typically issues within a few months of application, with the whole administration commonly running six to twelve months. Cross-border estates run longer - often twelve to twenty-four months - because a foreign grant, a local succession certificate or a tax clearance in another country has to be obtained before assets can be released, and those steps usually run consecutively rather than in parallel.
Can a foreign grant of probate be used in England?
Sometimes, by resealing. Under the Colonial Probates Act 1892 and the orders made under it, a grant issued in a listed Commonwealth or former Commonwealth jurisdiction can be resealed by the Probate Registry here and then operates as if granted in England and Wales. Grants from countries outside that list - the United States, most of the EU, the UAE - cannot be resealed, and a fresh English grant must be applied for instead.
Who administers an estate with assets in two countries?
Usually there is a primary administration in the jurisdiction of the deceased's domicile and an ancillary one wherever else assets sit. Getting the sequence right matters: an ancillary grant often requires the primary grant first, and applying in the wrong order costs months. Where two states each assert primary jurisdiction - which happens when domicile is genuinely contested - the position needs resolving before either application is made.
Do I need a grant at all?
Not always. Assets held as beneficial joint tenants pass by survivorship, and some institutions release modest balances on indemnity without a grant. But foreign assets almost always require formal authority, and any estate holding land in the deceased's sole name will need one.
Find out where your estate breaks
Twelve questions, two minutes, no account. The cross-border risk check flags the jurisdictions, the forced-heirship traps and the digital assets your current arrangements will not carry across.