The deceased lived in Scotland.
His beneficiaries are all based in England.
If the Scottish solicitor is drafting a Deed of Variation creating a trust, with all the trustees based in England, which law will the trust follow?
Scottish as it is a Scottish Will? Or English as the beneficiary creating the DoV is English?
I think there is freedom to choose either. Possibly determined by whichever legal system best suits the purpose of the trust.
I agree with @ALane, the governing law can be chosen by the parties - they could use the law of Jersey or New York if they so chose. If the document is being drawn by Scottish lawyers they will surely prefer to use Scottish law.