I own a property here in Wales and another in France which I want to be able to pass on to my children. Do I need separate Wills in each country to cover each property?

A Will made in each country will deal with the assets owned by you in that particular country. This is the rule predominately in European countries although you need to be very careful with regard to some countries where assets in a foreign country can be deemed to form part of the Estate of the deceased according to his Domicile of Residence.

A well known Court of Appeal case decided that assets held in Nigeria formed part of the estate of a deceased who died in the UK resulting in a huge inheritance tax liability to the Inland Revenue in this country as the law in Nigeria determined that assets in that country would follow the Domicile of Residence, not Domicile of Origin. The deceased was living in the UK so the Nigerian assets were included in the deceased’s UK estate for Inheritance Tax purposes!

EEC countries are consistent in that assets owned in that country are governed by the equivalent Inheritance Tax rules of that country. You, therefore, need to make separate Wills in the both countries in order to deal with your properties at home and abroad.