Cross-Border Inheritance Planning & Forced-Heirship Navigation
วางแผนมรดกข้ามพรมแดน + Forced Heirship (EU/ตะวันออกกลาง/CLMV) · § Family
What to know before you act
When the deceased holds assets in several countries, different laws can govern different assets. As a general rule immovable property follows the law of the country where it sits, while movables may follow domicile or nationality. Several jurisdictions — France, Japan and Shariah-based systems among them — apply forced heirship, reserving shares a will cannot fully exclude. We map which law governs each asset, coordinate with counsel in the destination country, and prepare separate jurisdiction-specific wills so a later will does not accidentally revoke an earlier one.
Timing and external dependencies: Structuring analysis takes several weeks; probate timelines vary widely between countries.
Official fee: Court fees and translation/legalisation costs differ by country — confirm with the relevant court and embassy before filing.
Timing is not a promise of an outcome or hearing date. Check the notice, limitation period and current authority rules for your matter.
What to send for the first review
Send every relevant page, a dated sequence of events, any hearing or filing deadline, and the outcome you need. This lets counsel identify urgent steps, missing evidence and a precise scope of work.
- Asset schedule + situs + valuation < 12 months
- Family tree + heir citizenship
- Domicile + tax residency certificate
Legal Basis
Thai CCC Book VI §§1599-1755 · EU Succession Regulation 650/2012 (Brussels IV) · Shariah Fara'id · Napoleonic forced heirship (FR/BE/ES) · Hague Succession 1989.
📚 Official sources — check the current law and procedure before acting
- กรมทรัพย์สินทางปัญญา— Department of Intellectual Property
- กรมการปกครอง — ทะเบียนครอบครัว— Department of Provincial Administration
- สำนักงานคณะกรรมการกฤษฎีกา — ตัวบทกฎหมายฉบับทางการ— Office of the Council of State
Who Needs This
Expats with multi-jurisdiction assets · Thais with children in EU/ME · Muslim families · mixed-nationality couples.
Required Documents
- Asset schedule + situs + valuation < 12 months
- Family tree + heir citizenship
- Domicile + tax residency certificate
- Prenup / postnup
- Prior wills + trust deeds
- Certified translation + Apostille.
Common Pitfalls
- One global will that is read as revoking the earlier ones
- Ignoring reserved shares, so the will is challenged abroad
- Forgetting that foreigners inheriting Thai land face Land Code restrictions
- Foreign documents not legalised and translated the way Thai courts require
Typical Use-cases
- German expat with Phuket + Berlin homes · Brussels IV German law · saved EUR 180K.
- Thai-Saudi family · Fara'id will + Labuan trust · Riyadh court cleared in 4 months.
- American · pour-over will + Delaware Trust · avoided US estate tax · saved USD 2.4M.
- Thai settlor + children in UK/AUS/USA · 4 mirror wills + trust · closed in 8 months.
FAQ
- Can a foreigner inherit land in Thailand?
- They can inherit the right, but continued ownership is restricted under the Land Code and often requires disposal within a set period — check case by case with the Land Department.
- How many wills should there be?
- Generally one per jurisdiction holding assets, each stating clearly that it does not revoke the others.
- Can heirs be disinherited in forced-heirship countries?
- Usually not for the reserved portion; planning runs through holding structures instead, and local counsel must confirm.
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Official sources — legal services
The information on this page follows the official sources below. Always check the latest version before you file.
- Office of the Judiciary— Office of the Judiciary
- Ministry of Justice— Ministry of Justice
- Lawyers Council of Thailand — Notarial Services Attorneys— Lawyers Council of Thailand
- Office of the Council of State — Thai law database— Office of the Council of State
- Royal Thai Government Gazette— Royal Thai Government Gazette
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Frequently asked questions
- Can a foreigner own 100% of a Thai company?
- Generally no for activities listed in the Foreign Business Act, where majority foreign ownership requires a Foreign Business Licence, a BOI promotion, or treaty rights such as the US–Thailand Treaty of Amity. Manufacturing and certain export activities are largely open, and BOI-promoted activities can permit full foreign ownership together with land-holding and visa privileges, so the right structure depends on the specific activity.
- What is the minimum registered capital for a Thai company?
- There is no general statutory minimum for a Thai-majority company, but practical thresholds apply: a fee quoted after review million of paid-up registered capital per foreign work permit, or a fee quoted after review million if the foreigner is married to a Thai national, and a fee quoted after review million per foreign shareholder for a Foreign Business Licence. Capital should therefore be planned around the visa and work-permit outcome you need, not the incorporation minimum.
- How long does company registration take?
- Registration at the Department of Business Development can be completed within one to three working days once the name reservation, shareholder documents and company objectives are ready, and the VAT registration and social security registration follow afterwards. The realistic end-to-end timeline including bank account opening is two to six weeks, with the bank account usually being the slowest step for foreign directors.
- What ongoing accounting obligations does a Thai company have?
- Every Thai company must keep statutory accounts, file monthly withholding tax (PND 1, 3, 53) and VAT (PP 30) returns by the middle of the following month, file the half-year corporate income tax return (PND 51) and the annual return (PND 50), and have its financial statements audited by a Thai CPA and filed with the DBD each year. Dormant companies are not exempt — nil returns and an audited statement are still required.