What are the pros and cons of having a choice of law clause in one worldwide will compared to the same choice of law clause in wills in several jurisdictions. The Lexis precedent I have found seems to be designed for the latter situation.
A relevant local court in a different jurisdiction might apply the chosen law as regards some if not all of the Will’s provisions, most obviously construction. Either because local law so applies or its PIL dictates renvoi. This might avoid the expense of making a Will in all other or just key jurisdictions, key because significant assets are situate there or beneficiaries are resident or have some other nexus to the jurisdiction.
It might be wise to at least research local probate requirements and succession law (such as forced heirship rules). If the point is important enough it may be worth seeking an opinion from a local expert, which may be more-cost effective than making a local Will. Otherwise a worldwide Will for a testator who has significant foreign assets or beneficiaries is in essence flying blind and I suggest the retainer should include a disclaimer and the engagement letter should record that the client desires to proceed, if he or she does, despite stated advice given as to the risk of not seeking clarification of any relevant foreign law.
Jack Harper
Not really answering your question but I suspect the main driver of producing separate wills for different jurisdictions is often the practical ones of speed and cost-efficiency should they have to be used.
The time aspect is that you can submit each to the relevant process at the same time, rather than, say, submit in the UK and then wait 3-6 months for a sealed copy to take overseas.
The costs aspect is the need for translations, affidavits of law or other steps required when filing a foreign will in a local jurisdiction - as well as the difficulty as ensuring that a worldwide will has the same effect in all of them - particularly where some may not have the concept of executors and/or forced heirship rights or might not understand any mention of trusts.