Inheritance and will planning for assets in two countries
For a family holding real estate, accounts and company shares in two countries, the choice of applicable law, the reserved-share analysis and the testamentary framework were structured so that they would not undermine one another across the two legal systems.
Two countries, two regimes, one family
A will drafted for a single country might not produce results against the reserved-share and formal rules of the other country.
The management of the company shares had to be planned separately from the distribution of the estate.
Our Approach
Keeping the commercial objective at the centre, we broke the legal risks into measurable steps.
01 · Regime Analysis
The applicable law and reserved-share effects were analysed in both frameworks.
02 · Document Set
The will and matrimonial-property documents were structured to comply with both legal systems.
03 · Share Structure
The company shares were tied to a structure that preserves management continuity.
Chronology
The main stages of the process.
A plan that does not split at the border
The family gained an inheritance framework that is valid in both countries, free of internal contradictions, and that preserves company continuity.
- A will framework valid under both laws
- Management of reserved-share scenarios
- A continuity structure for the company shares
- A single asset inventory
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