Dealing with an estate is already complex. When assets, family members or legal processes are spread across two countries, the paperwork can become even more difficult to manage.
A UK document that is valid for probate in the UK may not be accepted automatically by a foreign bank, lawyer, land registry or tax authority. It may need certification, legalisation, translation or embassy attestation before it can be used abroad.
When an estate involves two countries
An estate may involve more than one country if the deceased owned property abroad, held foreign bank accounts, received an overseas pension, had investments outside the UK or had family members living overseas.
It can also happen where the deceased lived abroad but held UK assets, or where a UK executor needs to deal with foreign authorities.
Each country may have its own rules for proving death, inheritance rights and authority to act.
Death certificate
A death certificate is usually one of the first documents requested.
For overseas use, this should normally be an original certificate or an official certified copy issued by the correct UK registration authority.
A photocopy, scan or emailed copy is unlikely to be accepted for formal estate matters abroad.
Grant of Probate or Letters of Administration
Foreign authorities may ask for proof of who has legal authority to deal with the estate.
If there is a will, this may be a Grant of Probate. If there is no will, or if the named executors cannot act, Letters of Administration may be required.
These documents may need to be official court-issued copies or solicitor-certified copies before they can be legalised.
UK will and supporting documents
A UK will may be requested by overseas lawyers, banks or registries to confirm executors, beneficiaries or the deceased person’s wishes.
Because a will is usually a private legal document, it may need solicitor or notary certification before legalisation.
Supporting documents may also be needed, including birth certificates, marriage certificates, deed polls, divorce documents or affidavits proving family relationships.
Overseas property and land registry matters
If the estate includes property abroad, the foreign land registry or notary may ask for legalised UK documents before the property can be transferred, sold or inherited.
This may include probate documents, death certificates, Powers of Attorney, identity documents for executors or beneficiaries, and evidence of family relationship.
Property-related documents often have strict format requirements, so the foreign lawyer’s instructions should be followed carefully.
Foreign bank accounts and investments
Banks abroad usually need documents before they will close accounts or release funds.
They may request a death certificate, probate document, will, identity documents for executors, proof of address, bank forms or family relationship evidence.
Passport copies and proof of address documents often need solicitor or notary certification before legalisation.
Translation requirements
If the foreign authority does not accept English documents, certified or sworn translation may be required.
The order should be checked before arranging translation. In many cases, the UK document is legalised first and translated afterwards so the translation includes the legalisation certificate.
Some authorities may also require the translation itself to be certified or legalised separately.
Embassy attestation for some countries
For countries that are members of the Hague Apostille Convention, UK legalisation is often the main authentication step.
For countries outside the Convention, embassy or consular attestation may also be required before the documents are accepted.
This should be checked early, especially where property, frozen accounts or tax deadlines are involved.
Coordinate before sending documents abroad
When an estate spans two countries, requirements can vary between banks, courts, lawyers, registries and tax authorities.
Before sending documents, ask the overseas lawyer or authority exactly what they need, whether originals or certified copies are accepted, whether notarisation is required, and whether translation or embassy attestation applies.
If you are dealing with an estate across two countries, 12 Apostille can review the UK documents, confirm the correct preparation route and help manage certification, legalisation or attestation where required.