A separate will made in UK by the UK client will be governed by UK law according to China law on choices of laws (private Internationa laws). So a will Iike this will have problem of being recognized as valid by China notary office if not probated in UK.
Please note that China does not have a probate process, meaning no court invention in the course of inheritance. When there is no dispute, we help clients get inheritance done by way of notarization which simplifies the process of inheritance of China estates by foreigners without resorting to courts in China.
If such a separate will made in UK can be easily probated in UK court, then it will much solve the problem of being recognized as valid by china notary office, which in turn will avoid the inheritance matter being elevated to court. That is the best option for clients.
Jason Tian
Shanghai Landing Law Office