Assets in several countries: probate, resealing and where a life policy fits

Singapore law as at 27 September 2026, for an individual living in Singapore with assets in more than one country. We state no processing times, because the Family Justice Courts publish none.

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What a grant does, and who issues it

A grant is the court's authority for a named person to collect and distribute a dead person's estate. The Family Justice Courts state: “The Family Justice Courts can appoint a person to manage the estate of a deceased individual through a grant of probate or letters of administration.” Probate is granted to an executor named in a valid will; letters of administration go to an administrator where there is no will, or no executor able to act.

Banks, share registries and the Singapore Land Authority deal with the person holding the grant. Until there is one, most assets in the deceased's sole name stay frozen. The family's first practical question is therefore not who inherits but what money can move before a grant exists.

A valid Singapore will

Under the Wills Act 1838, “No will made by any person under 21 years of age shall be valid” (s 4). A will must be in writing, “signed at the foot or end thereof by the testator, or by some other person in his presence and by his direction”, with the signature made or acknowledged “in the presence of 2 or more witnesses present at the same time”, who then sign in the testator's presence (s 6).

A will made elsewhere can still be valid here. Section 5(2) treats a will as properly executed if it conformed to the internal law of the place where it was executed, of the testator's domicile or habitual residence when it was executed or at death, or of the state of which the testator was a national at either time. A will disposing of land is also valid if it meets the law where the land is (s 5(3)(b)). A French national living in Singapore who signs a will in Paris in French form therefore does not need to re-sign it to satisfy Singapore formalities.

No will: the intestacy rules

Without a will, the Intestate Succession Act 1967 decides. Under section 7, a spouse with no children and no parents takes everything; a spouse with children takes one half, and the children share the other half “by equal portions per stirpes”; a spouse with no children but surviving parents takes one half, and the parents the other. The rules then run through siblings, grandparents, uncles and aunts, and finally to the Government. The Act does not apply to the estate of a Muslim (s 2); a Muslim estate is distributed by faraid under section 112 of the Administration of Muslim Law Act 1966.

Domicile decides movables; the location decides land

Section 4 of the Intestate Succession Act draws the line that matters most to international families. Movable property is distributed by “the law of the country in which he was domiciled at the time of his death”. Immovable property is distributed under the Act “wherever he may have been domiciled”.

Domicile is not tax residence. Tax residence in Singapore is an administrative test based on presence, 183 days or ordinary residence, as IRAS explains. Domicile is the legal home: the country where a person intends to stay permanently, which for many people who moved here as adults may still be the country they came from. A British engineer who has lived in Singapore for twelve years, owns a flat here and plans to retire to Cornwall may well be domiciled in England. If he dies without a will, his Singapore bank accounts and shares, as movables, pass under English intestacy rules, while his Singapore flat passes under section 7 of the Intestate Succession Act.

Land abroad is a matter for the country where it lies. As a general rule of private international law, which each country applies in its own way, a flat in London or a house in Perth is governed by the law and procedure of that place. A Singapore will can deal with it, but a Singapore grant will not by itself give anyone the power to sell it.

Resealing a foreign grant: section 47 of the Probate and Administration Act

When a grant already exists abroad, Singapore may accept it instead of starting again. Section 47 of the Probate and Administration Act 1934 allows a grant from “a court of probate in any part of the Commonwealth”, or from a country the Minister has declared by notification in the Gazette, to be “sealed with the seal of the Family Justice Courts”. Once sealed, it has “the like force and effect” as a grant made by the General Division of the High Court.

There are conditions. The court may require evidence of the deceased's domicile. If the deceased was not domiciled within the jurisdiction of the court that issued the grant, it is resealed only if it is a grant the General Division of the High Court would itself have made.

In practice this divides families into two groups.

• Commonwealth grants. A grant from England, Australia, India or Malaysia can be resealed, subject to the domicile condition.
• Other grants. A grant from a court in the United States, mainland China or most of continental Europe cannot be resealed unless that country has been gazetted. We could not verify the current list of gazetted countries, so check it before relying on either answer. Without resealing, the Singapore assets need a fresh Singapore grant.

Resealing only helps with Singapore assets. The reverse question, whether another country will accept a Singapore grant, is a matter for that country's law, and the answers differ.

Why assets in several countries multiply the work

Take a family with assets in four places. Each place applies its own rules on who may deal with the assets, which law divides them, what documents it needs, and in what language. Each may need certified copies of the death certificate, the will and the grant, and some will need translations and apostilles or legalisation. Where one country will not recognise another's grant, a second or third full application follows.

None of this makes the family poorer on paper, but it delays access to money, runs up legal fees in several currencies, and puts the estate in the hands of several sets of lawyers who may read the same will differently. The fewer places a family's assets sit in the deceased's own name, the fewer procedures there are.

Where a life policy with a named beneficiary fits

A Singapore policy with a Singapore nomination

A life policy issued by an insurer licensed in Singapore, governed by Singapore law and insuring the owner's own life is a “relevant policy” under section 131 of the Insurance Act 1966. If it carries a trust nomination under section 132, the policy moneys “do not form part of the estate of the policy owner”, and the insurer pays the trustees. If it carries a revocable nomination under section 133, the death benefits are distributed by the last unrevoked nomination rather than by the will or intestacy, subject to section 57 of the Probate and Administration Act on paying the estate's debts. Either way, the insurer does not need a grant to pay the nominee. The details, and the traps, are in our article on trust and revocable nominations.

Without a nomination, the Life Insurance Association Singapore explains that an insurer “may pay up to S$150,000 of the policy proceeds to any person who is considered a ‘proper claimant’ under section 150 of the Insurance Act 1966”. The rest waits for a grant.

A policy issued abroad

A policy issued by an insurer not licensed in Singapore, or governed by foreign law, is outside the Singapore nomination rules. Its beneficiary clause works under its own governing law. A beneficiary clause is designed to let the insurer pay the named person on proof of death, which can keep the money out of every country's probate procedure. Whether a particular policy does so, and what documents the insurer will ask for, is set by its terms and its law, so ask the insurer before relying on it.

The limits

• Only what is inside the policy. A policy can hold financial investments. It does not move the London flat or the shares held at a US broker, which still need their own procedures.
• The owner must be the life insured for Singapore nominations. If a husband owns a policy on his wife's life and dies first, the policy is an asset of his estate and needs a grant, whatever the beneficiary form says about her death.
• A revocable nomination does not escape the estate's debts. Section 133 is expressly subject to section 57 of the Probate and Administration Act.
• Forced heirship claims do not disappear. A payment to one child under a policy may be challenged in a country whose law reserves shares for all children. That depends on that country's law, not on Singapore's.
• Divorce. Insurance policies can be matrimonial assets under section 112 of the Women's Charter 1961, and in WRX v WRY [2024] SGHC(A) 22 a policy's value was treated as one.

Trusts, and the limits of the section 90 firewall

An asset that a trustee already owns at the settlor's death does not need a grant, because it is not the settlor's to pass. That is why international families often put a holding company, an investment portfolio or a life policy into a trust during their lifetime. Singapore trusts can last up to 100 years (Civil Law Act 1909 s 32), and a company that provides trust services here generally needs a licence under the Trust Companies Act 2005, with exemptions for private trust companies and some others that the Monetary Authority of Singapore lists.

Section 90 of the Trustees Act 1967 adds a firewall against foreign succession rules. A person creating a lifetime trust of movable property is treated as having capacity if he has it under Singapore law, the law of his domicile or nationality, or the proper law of the transfer (s 90(1)). Then, under section 90(2), “No rule relating to inheritance or succession affects the validity of a trust or the transfer of any property to be held on trust” if that capacity existed. Section 90(5) adds that reserving investment or asset management powers to the settlor does not by itself invalidate the trust.

The limits are in section 90(3). The firewall does not apply if the settlor “is a citizen of Singapore or is domiciled in Singapore”, and it applies only if “the trust is expressed to be governed by Singapore law and the trustees are resident in Singapore.” A Singapore citizen, or a foreigner who has become domiciled here, cannot rely on it. And a firewall in Singapore law binds Singapore courts; a court in the country whose forced heirship rules are said to be defeated may take its own view, especially about assets within its reach.

A worked example

Hypothetical, with every assumption stated. Mr and Mrs Adams are British nationals who have lived in Singapore for eleven years. Mr Adams, 61, intends to retire to England, and for this example we assume he remains domiciled in England. He dies in Singapore without a will. His assets:

Because Mr Adams died domiciled in England, an English grant is the natural starting point. It can be resealed in Singapore under section 47, since England is part of the Commonwealth and the grant comes from the court of his domicile. The Singapore condominium is divided under the Intestate Succession Act: Mrs Adams takes half, and their two children share the other half. The Singapore bank accounts, as movables, follow English intestacy law. The US account needs its own process. The only money that reaches the family without any grant is the S$2,000,000 under the trust nomination.

Now change one fact. If the policy had been issued by an insurer with no Singapore licence and named Mrs Adams as beneficiary, it would sit outside the Singapore nomination rules, and whether it paid her without a grant would depend on the policy's own terms and law. Change another: if the policy had carried a revocable nomination instead of a trust nomination, the death benefit would still go to the nominee, but the nomination would take effect subject to section 57 and the estate's debts.

A checklist for a family with assets abroad

1. List every asset by country, and note whose name it is in.
2. Decide, with a lawyer, where you are probably domiciled, and write down the facts that support it.
3. Make a valid will, and if you keep separate wills for different countries, make sure none revokes the others.
4. Check whether each country where you hold assets will accept a grant from the country of your domicile.
5. For Singapore policies, check that the nomination exists, is current, and names trustees who are not you.
6. For policies issued abroad, ask the insurer in writing what it needs to pay a beneficiary on death.
7. If you use a trust, confirm whether the section 90 firewall is available to you at all.

Where this sits in succession planning

The wider picture is on our page on succession planning in Singapore. For protection against creditors during life, see asset protection in Singapore and creditors, bankruptcy and a life policy. How a life insurance wrapper fits a family that lives in Singapore is explained on PPLI for Singapore residents. If you have a question about the research, ask a question.

Probate across borders: questions

Who issues probate in Singapore?

The Family Justice Courts. They appoint a person to manage the estate of a deceased individual through a grant of probate, where there is a will with an executor, or letters of administration, where there is not.

Can a foreign grant of probate be used in Singapore?

Only if it can be resealed under section 47 of the Probate and Administration Act 1934. That covers grants from a court of probate in any part of the Commonwealth and from countries gazetted by the Minister. The court may require evidence of domicile. A grant from elsewhere cannot be resealed, and a fresh Singapore grant is needed.

Which law decides who inherits a Singapore resident's assets without a will?

Under section 4 of the Intestate Succession Act 1967, movable property is distributed by the law of the country where the deceased was domiciled at death, and immovable property in Singapore is distributed under the Act whatever the domicile. The Act does not apply to Muslim estates, which follow faraid.

Is a will signed abroad valid in Singapore?

Usually. Section 5 of the Wills Act 1838 treats a will as properly executed if it complied with the law of the place where it was signed, the testator's domicile or habitual residence when signed or at death, or the testator's nationality. A will dealing with land is also valid if it complied with the law where the land is.

Does a life policy avoid probate in Singapore?

A policy issued by a Singapore-licensed insurer under Singapore law, on the owner's own life, with a trust or revocable nomination, is paid to the trustees or nominees without a grant. Without a nomination, the LIA says the insurer may pay up to S$150,000 to a proper claimant, and the rest needs a grant. A policy issued abroad depends on its own terms and law.

Does a revocable nomination protect the money from the estate's creditors?

No. Section 133 of the Insurance Act 1966 makes the nomination prevail over the will and intestacy, but expressly subject to section 57 of the Probate and Administration Act 1934, which governs how a deceased person's assets pay debts. Only a trust nomination takes the moneys out of the estate and away from the owner's debts.

Can a Singapore trust defeat forced heirship rules of my home country?

Section 90 of the Trustees Act 1967 says rules of inheritance or succession do not affect the validity of a lifetime trust of movable property if the settlor had capacity. It does not apply if the settlor is a Singapore citizen or domiciled in Singapore, and it requires a Singapore-law trust with Singapore-resident trustees. Courts abroad may take their own view.

How long does probate take in Singapore?

The Family Justice Courts do not publish a processing time, and we have not stated one. Timing depends on whether there is a valid will, whether a foreign grant can be resealed, whether anyone objects, and how many countries are involved.

Sources and authorities

Statutes (Singapore Statutes Online, 2020 Revised Edition): Probate and Administration Act 1934 s 47 and s 57; Wills Act 1838 ss 4 and 6 and s 5; Intestate Succession Act 1967 ss 2 and 4, s 7; Administration of Muslim Law Act 1966 ss 111 and 112; Insurance Act 1966 ss 131 and 132, s 133; Trustees Act 1967 s 90; Civil Law Act 1909 s 32; Women's Charter 1961 s 112. Courts and regulators: Family Justice Courts: probate and administration; MAS: licensed trust companies; IRAS: working out my tax residency. Case: WRX v WRY [2024] SGHC(A) 22. Industry guidance: LIA, Your Guide to Nomination of Insurance Nominees (2026).

Research checked 27 September 2026 against the statutes and official pages linked above. Our editorial standards explain how errors are corrected.

PPLI.com is not licensed by the Monetary Authority of Singapore and does not give financial advice. This is general information about Singapore law and other tax systems, not an offer or invitation to enter into any contract of insurance. Policies issued by insurers not licensed in Singapore are not covered by the Policy Owners' Protection Scheme or by the nomination rules in the Insurance Act 1966.