International Assets and Your Will in Singapore

Before you begin

If you are based in Singapore but have accounts or properties in other countries, the complexity of your estate will determine whether you need a single will or separate wills for each country. Assess your estate by checking:

• Do you have assets in more than 2 countries?
• Are the other countries governed by a different legal system than Common Law (which governs Singapore)?
• Do you have immovable properties (real estate) in other countries?

If you answered yes to two or more questions, you likely have a more complex estate.

How should I handle assets in multiple countries?

There are two courses of action:

Option 1: A single will

The benefit of a single will is that it consolidates managing your assets — there will be only one executor and one set of instructions, avoiding confusion over which will represents your last wishes.

However, a single will can extend the probate process since your estate will be settled sequentially in each country. This option works best if most of your assets are in Singapore with only a few accessible assets overseas, such as a bank account.

Option 2: Separate wills per country

Assets in different countries are subject to those countries' laws. Local courts examine whether wills meet their legal requirements. Multiple wills allow executors in each country to immediately pursue the court process without waiting for other jurisdictions to complete, reducing costs and administrative burden.

This approach is best for complex estates with significant assets across multiple jurisdictions.

Handling multiple wills

Standard practice includes revocation clauses to nullify previous wills. However, with international wills, your revocation clause must specify it applies only to properties in that country.

For example, if you have an existing UK will, your Singapore will should explicitly state that it revokes all previous wills pertaining to assets in Singapore and does not affect wills and assets in other countries.

Putting this into practice

For simple estates: Use a single will for all assets globally. Choose a country with fair and efficient operations to write your will.

For complex estates with Singapore assets:

• If you already have a will in another country, use MakeGoodwill to write a Singapore will designed to ensure other wills remain in effect.
• If this is your first will, write it in Singapore through MakeGoodwill.

What else can I do beyond making a will?

Merge your assets

Consolidate assets to simplify distribution — create a single investment portfolio or sell properties and deposit proceeds into one bank account.

Joint accounts

Right of survivorship means that if one account or property owner passes away, the other joint owner continues to have immediate and full access to that asset, without the need to go through probate. Convert accounts to joint ownership where permitted by law.

Creating a trust

Set up a trust where properties transfer to a trustee for designated beneficiaries. Properties placed in trust need not go through the probate process, and are directly passed to the beneficiaries.

Important: While these steps are useful, making a will remains essential. Without one, asset distribution follows local laws, potentially resulting in unwanted outcomes.