Administering an estate that spans two countries

When this situation arises

A person has died leaving assets in China and abroad, with heirs in more than one country and possibly more than one will.

The usual sequence

1. Separate the question of who inherits from the question of how each asset is released
2. Establish the applicable law for succession, which can differ between movables and immovables
3. Authenticate the death certificate, the will and the documents proving the heirs' relationship to the deceased
4. Open the procedures in each jurisdiction in parallel rather than sequentially

Where it usually stalls

Estates stall on relationship evidence. Institutions require proof of the family relationship, and assembling it across two countries takes longer than most families expect.

What is realistically achievable

Determining entitlement is usually the achievable part. Releasing the assets is the slower one, and each institution applies its own documentation requirements regardless of the succession outcome.

If your situation looks like this

Send the facts in one message: where the marriage was registered, where each party lives now, where any children are, and where the assets are held. That is usually enough to say whether a China route exists before any document is ordered, and there is no charge for that first review.

This note is general guidance on how such matters are usually handled. It is not a report of a specific case and it is not legal advice.

Points to take away

• Separate the question of who inherits from the question of how each asset is released
• Establish the applicable law for succession, which can differ between movables and immovables
• Determining entitlement is usually the achievable part. Releasing the assets is the slower one, and each institution app