IHT Double Taxation Relief UK 2026: s158 IHTA Bilateral Treaty Relief, s159 IHTA Unilateral Credit, US Estate Tax and UK IHT, and Cross-Border Estate Planning
If the same assets are taxed by both UK IHT and a foreign estate or inheritance tax, UK law provides either treaty credit relief (s158 IHTA) or automatic unilateral credit (s159 IHTA). US citizens in the UK face the most complex position — both countries claim worldwide taxation.
US Citizens in the UK: Both Countries Tax Your Worldwide Estate — The Treaty Reduces But Does Not Eliminate the Problem
A US citizen living in the UK for 10+ years (LTUK): pays UK IHT on worldwide assets AND US estate tax on worldwide assets (US citizenship = worldwide US estate tax regardless of residence). The US-UK Estate Tax Treaty (2002) provides credit relief — but does not create a perfect 0% double taxation outcome. You need both a UK IHT solicitor and a US estate tax attorney to model your estate and implement cross-border planning before death.
| Scenario | UK Rule | Key Details / Treaty | Planning Guidance |
|---|---|---|---|
| Bilateral treaty relief — s158 IHTA 1984 | BILATERAL TREATY RELIEF: where the UK has a double taxation convention with another country specifically covering inheritance/estate/gift taxes: s158 IHTA 1984 gives effect to the treaty. The treaty takes precedence over domestic law — the IHT treatment follows the treaty terms. HOW TREATIES WORK: most UK inheritance tax treaties use the 'credit method' — the country where the asset is SITUATED (the 'situs' country) has the primary right to tax. The other country (of residence/domicile) gives a credit against its own inheritance tax for the tax paid to the situs country. Example: UK resident dies owning a French house. France taxes the French house (as situs country) under French succession tax. UK also charges IHT on the French house (as part of the UK-resident/LTUK worldwide estate). The UK-France treaty: France has primary taxing rights over the French land. UK gives a credit against UK IHT for the French succession tax paid on the French house. Result: one country's tax (the higher one) is effectively the maximum charge on the French house. | UK INHERITANCE TAX TREATIES — CURRENT LIST (as at 2026): the UK has IHT-specific treaties with: (1) United States (Estate Tax Treaty 1978, revised by Protocol 2002 — most important); (2) France (Convention 1963 — covers successions and donations); (3) Italy (Convention 1966); (4) Netherlands (Convention 1946 — old but still in force); (5) Pakistan (Convention 1956 — estate duty treaty); (6) Sweden (Convention 1981 — covers gift and inheritance taxes); (7) Switzerland (Convention 1941 as updated — covers death duties); (8) South Africa (Convention 1978); (9) India (limited — old convention; position uncertain). NOTE: many countries do NOT have an IHT/estate tax treaty with the UK — including Australia, Canada, New Zealand, Germany, Spain, UAE, Singapore, Hong Kong. For estates with assets in those countries: s159 unilateral relief applies (see below), not a treaty. The treaties VARY significantly — do not assume treaty terms from one country apply to another. Read the specific treaty. | PLANNING IMPLICATION OF BILATERAL TREATIES: the treaty situs rules determine which country taxes which asset. For the US-UK treaty: US-situs assets (US real estate; US company shares; US bank accounts) are primarily taxed by the US; the UK gives credit. UK-situs assets (UK real estate; UK company shares; UK bank accounts) are primarily taxed by the UK; the US gives credit. The credit is limited: credit = lower of UK IHT on the doubly-taxed asset or the foreign tax on the same asset. Where the foreign tax EXCEEDS the UK IHT on the asset: no top-up; the UK does not refund the foreign excess. Where UK IHT EXCEEDS the foreign tax: UK IHT is charged on the difference (the foreign tax credit reduces but does not eliminate the UK IHT). The estate planner's goal: ensure assets are in the right jurisdictions; use treaty situs rules to optimise the overall tax position across both countries; and ensure the credit mechanism is correctly applied by executors in both jurisdictions. |
| Unilateral relief — s159 IHTA 1984 (no treaty country) | UNILATERAL RELIEF (s159 IHTA 1984): where there is NO inheritance/estate tax treaty between the UK and the foreign country: s159 provides automatic credit relief. No claim is needed to invoke s159 (it applies automatically to qualifying assets). HOW s159 WORKS: (1) The estate owns assets in a foreign country (no UK tax treaty). (2) The foreign country imposes its own inheritance/estate/succession tax on those assets. (3) The UK also charges IHT on the same assets (because the deceased was LTUK or UK-domiciled and the worldwide estate is in scope). (4) s159 credit = the lower of: (a) UK IHT attributable to the doubly-taxed foreign assets; and (b) the foreign tax paid on those assets. (5) The credit is set against the UK IHT — reducing the UK IHT bill. The relief is calculated ASSET BY ASSET (not country-wide): the credit is limited to the UK IHT on the specific doubly-taxed assets, not the overall UK IHT on the whole estate. | CALCULATING THE s159 CREDIT — WORKED EXAMPLE: UK estate total = £2m (LTUK — worldwide IHT). Spanish holiday home value = £400k. Spanish succession tax on the holiday home = £60k (18% rate). UK IHT on the estate: total = £2m; NRB = £325k; taxable estate = £1.675m; IHT rate = 40%; UK IHT = £670k. UK IHT ATTRIBUTABLE to the Spanish house: £400k / £2m × £670k = £134k. s159 credit = lower of (a) UK IHT attributable to Spanish house = £134k OR (b) Spanish tax = £60k → credit = £60k. UK IHT net = £670k − £60k = £610k. The s159 credit reduced UK IHT by £60k (the full amount of the Spanish tax). The Spanish house was still taxed at the Spanish rate (£60k); the UK IHT on the Spanish house was reduced from £134k to £74k (net IHT on the house = £60k Spanish + £74k UK = £134k total, same as the UK IHT would have been alone — because the Spanish tax was less than the UK IHT on the same asset). | COUNTRIES WITHOUT INHERITANCE TAX — DOUBLE BENEFIT: some countries have NO inheritance tax at all (for example: Australia, Canada, New Zealand, UAE, Singapore, Hong Kong). If an LTUK individual owns assets in Australia: Australia does not charge inheritance tax on those assets. The UK charges IHT on the Australian assets (as part of the LTUK worldwide estate). s159 credit: NO credit available (there is no foreign tax to credit). The Australian assets are fully within UK IHT. There is no double tax (only UK IHT) — but also no overseas relief. PLANNING FOR NO-TAX JURISDICTIONS: ensure the LTUK individual's estate plan accounts for full UK IHT on all overseas assets in no-tax countries. Consider whether to settle these assets into an excluded property trust BEFORE becoming LTUK (see the domicile/LTUK blog). Consider using UK NRB/RNRB to cover these assets. Consider lifetime gifts (PETs) of these assets. |
| US citizens in the UK — the double domicile problem | THE UNIQUE US CITIZEN POSITION: US citizens (including US citizens who have lived in the UK for many years) face a uniquely difficult cross-border tax position: (1) UK IHT: if LTUK (resident 10+ of last 20 UK tax years from 6 April 2025): IHT applies to WORLDWIDE assets. (2) US ESTATE TAX: the US charges estate tax on the worldwide assets of ALL US citizens — regardless of where they live or their UK tax status. Unlike most countries (which base their estate tax on residence or domicile): the US uses CITIZENSHIP as the basis for worldwide estate tax. A US citizen who has lived in London for 30 years, owns no US assets, and has no ties to the US: still pays US estate tax on their worldwide estate on death. The current US estate tax exemption (unified credit) is approximately $13.6m per person (2024 — but scheduled to reduce sharply from 2026 unless extended by Congress). If the worldwide estate is below the US exemption: no US estate tax. Above: US estate tax at up to 40% on the excess. | THE US-UK ESTATE TAX TREATY (1978, as amended by Protocol 2002): the treaty provides credit relief to eliminate (or reduce) double taxation on the same assets. KEY TREATY PROVISIONS: (1) SITUS RULES: the treaty defines where different assets are 'situated' for treaty purposes — US real estate is US-situs; UK real estate is UK-situs; shares in US companies are US-situs; shares in UK companies are UK-situs; bank accounts follow the branch location. (2) CREDIT MECHANISM: the situs country has primary taxing rights; the other country gives credit for the tax paid by the situs country; the credit cannot exceed the other country's tax on the same asset. (3) US UNIFIED CREDIT: the treaty allows a non-domiciliary of the US (a UK-LTUK individual who is also a US citizen) to claim a pro-rated unified credit based on the proportion of the estate that is US-situs. This is important for US citizens living in the UK with mixed US and UK assets. The treaty does NOT cover all taxes: it covers US federal estate tax and UK inheritance tax. It does NOT cover: UK capital gains tax; US income tax; UK stamp duty. State estate taxes (e.g., Massachusetts, New York) are NOT covered by the treaty. | PLANNING FOR US CITIZENS IN THE UK: (1) GET SPECIALIST DUAL-QUALIFIED ADVICE: you need both a UK IHT specialist (solicitor or tax adviser) AND a US estate tax attorney. The interaction of UK IHT, US estate tax, and the treaty is highly complex. Do NOT rely on either UK-only or US-only advisers for the overall plan. (2) UNDERSTAND YOUR COMBINED ESTATE TAX POSITION: model the total estate across UK and US taxes. Apply the treaty credit. Determine whether the combined charge (after treaty relief) is acceptable or requires planning. (3) WILLS: you will need BOTH a UK will (covering UK-situs assets) and a US will (covering US-situs assets and US citizenship-specific provisions). The wills must be coordinated — both should reference the other and ensure they do not inadvertently revoke each other. (4) SPOUSAL EXEMPTION DIFFERENCES: the US estate tax marital deduction (for transfers to a US citizen spouse) is unlimited. The marital deduction for transfers to a NON-US-CITIZEN spouse is limited to approximately $185,000 per year (annual exclusion — not a full deduction). A QTIP trust or qualified domestic trust (QDOT) may be used for non-US-citizen spouses. UK side: s18 IHTA spouse exemption is unlimited for UK-domiciled recipients; capped at £325k for non-UK-domiciled recipients. The interaction of these rules for a US-UK mixed nationality couple requires very careful planning. |
| French succession tax and UK IHT — the UK-France treaty | UK-FRANCE INHERITANCE TAX TREATY (CONVENTION 1963): the UK has a double tax convention with France covering inheritance and succession taxes. France charges 'droits de succession' (succession tax) on: (a) assets in France (wherever the deceased was domiciled); (b) the worldwide assets of persons domiciled in France at death. UK charges IHT on: (a) UK-situs assets (wherever the deceased was domiciled); (b) worldwide assets of LTUK/UK-domiciled persons. OVERLAP: if a person is both LTUK for UK IHT and domiciled in France for French succession tax: both countries charge on the worldwide estate. The UK-France treaty resolves this via credit relief: the treaty allocates taxing rights based on the 'fiscal domicile' of the deceased and the situs of the asset. Where a UK resident dies owning a French property: France taxes the French property (situs); UK gives a credit for French succession tax paid on the French property against UK IHT. The French rate varies by relationship: 5-45% for direct descendants; 35-45% for siblings; 55-60% for non-relatives. The UK credit reduces the UK IHT on the French property by the French tax paid. | FRENCH FORCED HEIRSHIP AND UK ESTATES: France has 'forced heirship' (réserve héréditaire): children have a MANDATORY right to receive a proportion of the estate. This is a private international law (succession law) issue — separate from IHT. The EU Succession Regulation (Brussels IV) allows individuals to elect the law of their habitual residence to govern the succession to their estate (rather than the law of the situs of each asset). A UK-habitually-resident person with French property: can elect UK law to govern the succession (avoiding French forced heirship for the French property). This election should be made in the will. However: the French succession TAX still applies to French-situs assets regardless of the succession law election (the election covers succession law — who inherits; not tax). The UK-France treaty credit applies regardless of the succession law election. | PLANNING FOR UK-FRANCE ESTATES: (1) ENSURE THE WILL ELECTS UK LAW (if desired) to avoid French forced heirship — a Brussels IV election in the UK will. (2) OBTAIN FRENCH TAX ADVICE on the French droits de succession on the French property — the French tax must be calculated and paid before the UK IHT credit is applied. (3) COORDINATE UK AND FRENCH EXECUTORS: a notaire in France handles the French succession and French tax. The UK executors (personal representatives) handle the UK IHT. The two processes must be coordinated to ensure the French tax credit is correctly applied on the UK IHT return (IHT400). (4) LIFETIME GIFTS OF FRENCH PROPERTY: gifts of French property during lifetime may be subject to French gift tax (droits de donation) — similar rates to succession tax; separate from IHT. The UK-France treaty also covers gift taxes. Specialist UK and French tax advice is needed before gifting French property. |
| Situs of assets for double taxation relief — which country taxes which asset | SITUS OF ASSETS — WHY IT MATTERS FOR DOUBLE TAXATION RELIEF: the situs (location) of an asset determines which country has primary taxing rights under a treaty. If there is no treaty: situs determines whether s159 unilateral relief is available (only for foreign-situs assets taxed by a foreign country). UK SITUS RULES (s150-s151 IHTA 1984): (1) Land and buildings: situs = where the land is physically located (UK land = UK-situs; French land = French-situs). (2) Shares in a company: situs = the country of incorporation of the company (shares in a UK-incorporated company = UK-situs, regardless of where the shareholder lives or where the shares are held). (3) Bank accounts: situs = where the bank branch is located (or the country of the bank for online accounts — specialist advice). (4) Debts: situs = where the debt is recoverable (UK debts are UK-situs). (5) Tangible moveable property (jewellery, art, furniture): situs = where the property physically is at the date of death. (6) Life assurance policies: situs = where the policy can be enforced — typically where the insurer is established. | SITUS RULES UNDER TREATIES — MAY DIFFER FROM DOMESTIC RULES: the treaty may define situs differently from domestic UK law. The US-UK treaty has its own situs rules (which generally follow domestic law but with specific carve-outs). The French treaty also has specific situs rules. ALWAYS check the specific treaty situs rules — domestic UK situs rules (s150-s151 IHTA) apply only where there is no treaty (or where the treaty is silent). COMMON SITUS ISSUES: (a) Shares held through an offshore nominee/custodian: the shares are situs in the country of incorporation of the UNDERLYING company — not where the nominee/custodian is located. (b) A UK investor holding shares in a US company through a UK stockbroker: the shares are US-situs (US company = US-situs) — US estate tax may apply to these shares (if the holder is a US citizen or is non-resident alien with US-situs property above the US estate tax non-resident threshold of $60,000). (c) UK-listed shares held in a US custody account: UK-situs (UK company) — UK IHT; not US estate tax primary (unless the holder is a US citizen: then both). | PRACTICAL STEPS FOR CROSS-BORDER ESTATES: (1) INVENTORY ALL ASSETS BY SITUS: before death (or as part of estate administration after death): map every asset to its situs country. Identify which assets are doubly taxed. (2) IDENTIFY APPLICABLE TREATY OR s159: for each doubly-taxed asset — does a bilateral treaty apply (s158 IHTA)? If yes: follow the treaty credit rules. If no treaty: s159 unilateral relief. (3) CALCULATE AND CLAIM ALL CREDITS: executors must calculate the credit for each doubly-taxed asset and include it in the UK IHT400. Failure to claim the credit (by executor oversight or ignorance) results in overpayment of UK IHT — which can be recovered via amendment of the return (within the applicable time limits). (4) FOREIGN PROBATE/SUCCESSION PROCEEDINGS: where assets are held in a foreign country, foreign probate or succession proceedings may be required. The foreign tax paid in those proceedings is the basis for the credit in the UK. (5) CURRENCY: the foreign tax and the UK IHT credit are both computed in GBP (sterling) — using the exchange rate at the date of death for the conversion. HMRC's practice: use the exchange rate on the date the tax was paid or due (seek guidance from HMRC where there is uncertainty). |
IHT double taxation relief UK 2026. s158 IHTA 1984: double taxation conventions — 'If provision is made by any arrangements having effect under any enactment for relief from any tax chargeable in the United Kingdom and a foreign tax, the tax chargeable under this Act shall, subject to the arrangements, be reduced in the case of any assets by the amount of the foreign tax chargeable in respect of those assets.' Section 158(1) IHTA 1984 gives effect to double taxation conventions by order in council — each treaty is incorporated into domestic law by statutory instrument. The existing UK IHT treaties: United States — The Estate Tax Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America, signed 19 October 1978 (Cmnd 7483), as amended by the Protocol signed at London 31 March 2002 (the 2002 Protocol substantially updated the treaty, particularly adding provisions for the unified credit for non-domiciliaries and updating the situs rules); France — Convention between the United Kingdom and France for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Estates, Inheritances and Gifts, signed 21 June 1963 (SI 1963/1319); Italy — Convention 1966; Netherlands — Convention 1946; Sweden — Convention 1981; Switzerland — Convention 1941 as updated; South Africa — Convention 1978; Pakistan — Convention 1956; India — Convention with specific and limited coverage (check current status). s159 IHTA 1984: unilateral relief — 'Where any property is comprised in a person's estate immediately before their death and a foreign tax (not covered by arrangements under s158) is imposed on that property as a result of the death, then, to the extent that the tax attributable to the value of that property does not exceed the foreign tax, relief is given by reducing the UK tax attributable to that property.' s159 applies automatically (no election needed). 'Foreign tax' means a tax charged under the law of a foreign country in respect of a disposition of property on death; it must be a tax charged on the same property as the UK IHT (doubly-taxed). The credit is the LOWER of the UK IHT attributable to the doubly-taxed property and the foreign tax on that property. UK situs rules: s150 IHTA 1984 — 'the situation of property for the purposes of this Act shall be determined as it would be determined for the purposes of an action in the UK courts'. The UK courts follow common law situs rules: land and buildings — situs = location; shares — situs = country of incorporation of the company; debts — situs = where the debt is properly recoverable (place of performance); tangible movables — situs = location at date of death. The US-UK Estate Tax Treaty (1978 as amended 2002): Articles of particular importance: Article 8 (credit mechanism); Article 7 (situs of property); Article 11 (non-discrimination); Protocol 2002 Article VII (unified credit for non-domiciliaries). US estate tax: Internal Revenue Code ss2001-2210 for US citizen/domiciliary estates; ss2101-2108 for non-resident aliens (only US-situs property subject to US estate tax). US estate tax rates: 18-40% for taxable estates above $10,000 (graduated); the unified credit eliminates tax on estates below approximately $13.61m (2024 per person — but scheduled to reduce to approximately $7m in 2026 if current law sunsets; Congress may extend). Non-resident aliens (non-US citizens not domiciled in US): US estate tax on US-situs property only; $60,000 exemption (not the unified credit — the unified credit is for US citizens and US domiciliaries only). US-UK treaty pro-rated unified credit: Article 8(4) of the 2002 Protocol — a UK-domiciled (or LTUK) individual who is also a US citizen (or non-US citizen non-domiciliary of the US) can claim the US unified credit on a pro-rated basis: credit = US unified credit × (US-situs estate / worldwide estate). This is more generous than the $60,000 non-resident exemption. IHT417 form: HMRC supplementary pages to IHT400 for assets outside the UK — used to report foreign assets and claim double taxation relief. Filed with the IHT400. HMRC guidance on double taxation relief: IHTM27000 — HMRC's IHT manual chapter on double taxation relief (available on HMRC website). The Brussels IV Regulation (EU No 650/2012 on succession): allows individuals habitually resident in an EU member state to elect the law of their nationality to govern the succession to their estate. A British national habitually resident in France: can elect English law to govern succession (avoiding French forced heirship). Post-Brexit: the UK is not an EU member state — this election must now be made in the will (rather than relying on Brussels IV automatically applying the nationality election post-Brexit). Seek specialist advice on post-Brexit succession law elections for UK residents with EU assets.
Frequently Asked Questions
What is double taxation relief for inheritance tax?
Double taxation relief for IHT applies when the same assets are taxed by both UK IHT and a foreign country's inheritance or estate tax. UK law provides two types of relief: (1) BILATERAL TREATY RELIEF (s158 IHTA 1984): where the UK has a double taxation convention with the foreign country covering inheritance taxes — the treaty provides credit relief, typically with the situs country taxing first and the other country giving credit. The UK has treaties with: the US (Estate Tax Treaty 2002), France, Italy, Netherlands, Sweden, Switzerland, South Africa, Pakistan, and India (limited). (2) UNILATERAL RELIEF (s159 IHTA 1984): where there is NO treaty — automatic credit for the foreign tax paid, limited to the lower of: (a) the UK IHT attributable to the doubly-taxed assets; or (b) the foreign tax paid. The credit is applied against the UK IHT bill — reducing it by the foreign tax (up to the UK IHT on those specific assets). Neither relief is a deduction from the estate value — both are credits against the UK IHT itself.
How does the US-UK Estate Tax Treaty work for UK residents?
The US-UK Estate Tax Treaty (1978, revised by Protocol 2002) prevents full double taxation for estates subject to both UK IHT and US estate tax. Key features: (1) SITUS RULES: the treaty defines which country has primary taxing rights over each type of asset. US real estate and US company shares are US-situs; UK real estate and UK company shares are UK-situs. The situs country taxes first; the other country gives credit. (2) CREDIT MECHANISM: the country with secondary taxing rights credits the tax paid to the primary country against its own tax — credit is limited to the lower of its own tax or the primary country's tax on the same asset. (3) US CITIZENS' UNIFIED CREDIT: US citizens who are non-domiciliaries of the US can claim a pro-rated unified credit under the treaty (proportional to the US-situs assets as a fraction of the worldwide estate). WHO NEEDS THIS: US citizens living in the UK for 10+ years (LTUK under FA 2025) face both UK IHT (worldwide) and US estate tax (worldwide — based on citizenship). Specialist advice from both a UK IHT solicitor and a US estate tax attorney is essential.
What double taxation relief is available for French property owned by a UK resident?
The UK-France double taxation convention (1963) covers inheritance and succession taxes. If a UK LTUK/domiciled person dies owning French real estate: France taxes the French property (as situs country) under droits de succession. The UK also charges IHT on the French property (as part of the worldwide estate). The treaty provides credit relief: UK gives credit against UK IHT for the French succession tax paid on the French property. Credit = lower of (a) UK IHT attributable to the French property or (b) French succession tax on the French property. Practical: the French notaire handles the French succession and tax; the UK personal representative includes the French property in the IHT400 and claims the credit for French tax paid. French forced heirship (réserve héréditaire): a UK resident can elect UK succession law (Brussels IV) in their UK will to avoid forced heirship — this does not affect the French succession tax liability. Both a UK IHT specialist and a French notaire are needed for these estates.
What is s159 IHTA unilateral relief and when does it apply?
Section 159 IHTA 1984 provides automatic unilateral relief where an overseas country charges inheritance/estate tax on the same assets as UK IHT AND there is no bilateral treaty between the UK and that country. Examples of countries without a UK IHT treaty: Australia (no inheritance tax — no relief needed anyway), Canada (no inheritance tax), Spain, Germany, UAE, Singapore. Where a country WITH inheritance tax but WITHOUT a UK treaty (e.g., a European country not listed in the UK's treaty network): s159 unilateral relief applies. HOW IT WORKS: credit = lower of (a) UK IHT attributable to the doubly-taxed foreign assets; OR (b) the foreign tax paid on those assets. Applied ASSET BY ASSET (not country-wide). The credit reduces the UK IHT bill — it cannot increase a refund. Where the foreign country has NO inheritance tax: s159 does not apply (there is no foreign tax to credit); the UK IHT applies in full to foreign assets in the LTUK worldwide estate.
How do I include double taxation relief on the UK IHT400?
Double taxation relief is claimed on HMRC Form IHT400 (the main IHT return on death). The relevant supplementary page is IHT400, page 7 (or the relevant schedule for foreign assets — IHT417 for foreign assets). The executor must: (1) include the full value of the foreign assets in the IHT400 (do NOT exclude them — they are within the UK estate for a LTUK/UK-domiciled deceased); (2) on the relevant schedule: show the foreign tax paid on each doubly-taxed asset; (3) calculate the credit under the treaty (s158) or unilateral rule (s159); (4) enter the credit on the IHT400 to reduce the overall IHT payable. TIMING: the credit can only be claimed once the foreign tax has actually been paid (or assessed). Where the foreign probate/succession process is slow: an initial IHT400 may be submitted without the credit; the credit is then claimed via an amendment to the IHT400 once the foreign tax is settled (within the 4yr enquiry window). Executors should seek HMRC's guidance on the IHT417 and the specific treaty/unilateral relief claim forms. Specialist advice is strongly recommended for all cross-border estates.
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