Cross-border estate planning: assets in Hong Kong, the UK and Singapore — how does the family deal with them?

Illustrative scenario: Raymond's assets are spread across three places — what's the problem?

Illustrative scenario (for explanation only, not a real client): Raymond, 58, is an experienced investor with two properties in Hong Kong, a rental flat in the UK, plus bank and share accounts in Singapore — total assets estimated at over HK$30 million. He assumed spreading assets made them safe, but never told his wife where each account was. If he died suddenly, the problem would not be too few assets, but that his family could not find them or get them out: his wife may not even know which overseas accounts exist, and the UK and Singapore assets would need to go through local procedures.

• Opaque assets: family don't know which bank, brokerage accounts and policies exist.
• Fragmented procedures: Hong Kong, the UK and Singapore may each need a grant or recognition.
• Cash-flow gap: until procedures are complete, assets in the deceased's sole name generally cannot be used.

What if the family doesn't know which accounts exist?

The most practical step is to build an 'asset map' during your lifetime: list each asset's location, institution, account type, contact person and where the documents are kept, and tell your executor or family where to find it. The most common problem with cross-border assets is not that they disappear, but that the family doesn't know they exist — so they become long-unattended 'dormant accounts'. An asset map doesn't need passwords; the point is that the executor knows 'what there is, where it is and whom to contact', alongside making a will that names the executor.

1. Step 1: list assets by placeList property, bank accounts, brokerage accounts, MPF/retirement schemes, insurance policies and company shares in Hong Kong, the UK, Singapore and elsewhere, item by item.
2. Step 2: note institutions and contactsFor each asset, note the bank/insurer/broker, account type, the contact details of any local solicitor or accountant, and beneficiary details (where relevant).
3. Step 3: note where documents are keptRecord where the original will, title deeds, policies and account documents are kept, and tell your executor; never write passwords directly on the list.
4. Step 4: cross-check against wills and beneficiariesCheck that assets in each place are covered by a will and that policy beneficiaries match your overall wishes, avoiding contradictions.
5. Step 5: update regularlyAfter opening or closing accounts, buying or selling property, relocating or a change in family circumstances, update the asset map and inform your executor.

An asset map is a personal organising tool and does not replace a will or other legal documents; it involves privacy and security, so keep it safely.

Do overseas assets need a separate grant in each place?

Generally, yes. A Hong Kong Grant of Probate or Letters of Administration mainly deals with Hong Kong assets; assets in the UK, Singapore and elsewhere usually need a local grant, or recognition of the Hong Kong grant (for example resealing, where available). Procedures, document requirements, costs and timing vary by place, often requiring local lawyers and possibly notarisation and translation of documents. For the Hong Kong side, see probate in Hong Kong; the time needed depends on the estate's complexity and can range from a few months to longer, while the overseas side depends on local procedures.

Procedures, costs and timing vary and follow the latest requirements of local courts and institutions; for the UK, subject to the latest HM Revenue & Customs (HMRC) rules. General education only, not legal or tax advice; consult a solicitor/tax adviser and a licensed insurance intermediary for your arrangements.

Is UK property subject to inheritance tax, and why 'pay the tax first, receive the assets later'?

It may be. Under HM Revenue & Customs (HMRC) rules, UK-situated assets (such as UK property) are generally within UK Inheritance Tax even if the deceased was not UK-resident; the standard rate is 40% on value above the £325,000 nil-rate band. Because UK IHT generally has to be paid (or arranged) before a UK grant can be obtained, the family may need to raise the tax before they can use the UK assets — on top of local legal fees, notarisation and other cross-border costs — creating cash-flow pressure. By contrast, Hong Kong has abolished estate duty and Singapore abolished estate duty in 2008, so of the three places, UK assets are the ones that most need advance attention to tax and liquidity.

• Tax base: UK asset value above the £325,000 nil-rate band, standard rate 40%.
• Sequence: IHT generally has to be paid or arranged before a UK grant can be obtained.
• Cash flow: the family may need to use other funds, sell other assets or borrow.

Subject to the latest HM Revenue & Customs (HMRC) rules; tax rules can change and the actual liability depends on individual circumstances. General education only, not legal or tax advice; consult a solicitor/tax adviser and a licensed insurance intermediary for your arrangements.

Should you make a separate will in each place where you hold assets?

It depends, but many people with cross-border assets consider wills arranged by where the assets sit — for example one covering Hong Kong assets and one covering UK assets, each drafted by a lawyer familiar with local law — which may help local procedures run more smoothly. The key is that the wills must work together: a will usually contains a clause 'revoking all previous wills', and if worded carelessly, a later will could accidentally revoke the earlier one, leaving some assets to be dealt with as if there were no will. So each will should state clearly which place or assets it covers, and the lawyers in each place should be aware of one another. For the basics, see how to make a will.

• Clear scope: each will states which place or type of asset it covers.
• No mutual revocation: revocation clauses must be drafted carefully so one will doesn't cancel another.
• Executors: consider appointing suitable executors in each place to handle local procedures.
• Review together: whenever one will changes, check whether the others need to follow.

Multiple-will arrangements involve the law of each place and must be handled by lawyers. General education only, not legal or tax advice; consult a solicitor/tax adviser and a licensed insurance intermediary for your arrangements.

What role can life insurance play in a cross-border estate?

Life insurance can be one tool for setting aside liquidity: a death benefit with a named beneficiary generally does not go through probate (subject to policy terms), so the family may have funds for living costs, legal fees and even UK inheritance tax while grants in each place are pending. However, payout timing depends on the insurer and the claim documents; and insurance is only one tool, not the whole answer: premiums rise with the age at which you buy, underwriting applies (health may affect acceptance or premiums), and the sum insured should be affordable. Insurance should be considered alongside wills, the asset map and, in more complex cases, arrangements such as a family trust; for the overall approach, see wealth succession.

• Purpose: set aside liquidity for costs, legal fees and taxes while grants are pending.
• Limits: premiums rise with age, underwriting applies, the sum insured must be affordable; terms follow each policy.
• Coordination: beneficiary arrangements should match your wishes in each will and be reviewed regularly.

Insurance arrangements follow each policy's terms. General education only, not legal or tax advice; consult a solicitor/tax adviser and a licensed insurance intermediary for your arrangements. For help putting the pieces together, see how we help.