I am dealing with an estate where the deceased died domiciled in Spain with a Spanish Will. The Spanish Will is limited to Spanish assets only and leaves Spanish assets to spouse. There is no UK Will and one UK Bank Account.
I’m not sure about how the UK Bank Account passes. I have considered the following options:
To spouse under UK intestacy laws despite the deceased having died domiciled/habitually resident in Spain - on the basis that UK bank account is movable property so UK succession laws apply;
To children under Spanish intestacy laws - on the basis that deceased died habitually resident in Spain and movable/immovable property is irrelevant, but the Spanish Will is limited to Spanish assets and so Spanish intestacy must apply; or
To spouse under Spanish Will despite the Spanish Will being limited to Spanish assets.