Richard Frimston kindly raised the point on Linked In that were assets to be situated in the United Kingdom and therefore subject to probate within the UK, there would be a risk of contagion, and a fiscal risk that non-UK assets would be brought into charge through the probate procedure. I would suggest that in that case, it would be wiser to execute one will for UK situs assets, subject to the usual internal jurisdictional issues for probate within the UK, and a separate will or wills for, property outside it also expressly subject to the nationality option so as to ensure that the entire succession was dealt with under the law of the testator’s nationality for Regulation purposes.
Each case to itself.
Peter Harris