A British retiree who died in Chiang Mai in early 2025 had a perfectly valid will drawn up by a solicitor in Bristol, notarised and everything. It named his two children as equal heirs to his condo, his savings and a small share portfolio back home. What it did not do was get his family a single baht faster. The Thai condo sat frozen for fourteen months while a family court in the UK issued a grant of probate, a certified translator rendered it into Thai, the Chiang Mai Land Office queried whether the building's foreign-ownership quota still had room, and a lawyer in Bangkok explained, more than once, that a foreign will has no automatic standing in a Thai land registry. His daughter, who flew out twice during those fourteen months just to sign forms in person, ended up paying more in translation and courier fees than most people spend furnishing the apartment in the first place.
This is the part of expat life almost nobody plans for, because it only matters once, and by then you are not the one dealing with it. Most people assume a will made at home covers everything they own, wherever it happens to be. It doesn't. Property, bank accounts, provident-fund savings and land-use rights are governed by the law of the country where the asset sits, not the law of the country where you signed the paperwork, and five of the region's biggest expat destinations each handle that split in a completely different way.
Thailand: your condo can pass to your children, your land almost never will
Thailand lets foreigners own condominium units outright, but only within a 49% foreign-ownership cap per building under the Condominium Act B.E. 2522 (1979). When a foreign heir inherits a unit, the Land Department still checks that cap, and the heir still has to prove the original purchase money came from abroad — the same Foreign Exchange Transaction (FET) form the deceased needed when buying. If that paperwork is missing, or the building's foreign quota is already maxed out by other units, the heir is typically given one year to sell the unit and take the proceeds instead of the title. A mid-range one-bedroom in Chiang Mai or Pattaya runs THB 3–5 million (roughly $85,000–140,000), and that is the sum an heir can end up chasing through a forced sale rather than simply keeping the keys.
Land is the harder wall. Foreigners cannot hold freehold land title under the Land Code Act, full stop, and that restriction does not soften on death. If a foreigner inherits land from a Thai spouse or relative — a house plot, a rai of farmland, anything registered as land rather than a condo unit — the Land Department applies Section 94 and gives the foreign heir a fixed window, commonly one year, to sell. Buy a Thai will drafted by a local lawyer that deals only with your Thai assets; it is cheap, usually a few thousand baht, and it removes months of translation and authentication that a foreign will otherwise forces on your family.
Singapore: no forced heirship, but your CPF ignores the will entirely
Singapore is unusually generous to testators. There is no forced heirship rule of the kind common in France or Vietnam — you can leave your entire estate to one child, a charity, or a friend, and the Intestate Succession Act only kicks in if you die without a valid will (Muslim residents instead fall under the Administration of Muslim Law Act, with shares fixed by a Syariah Court inheritance certificate). That flexibility, though, does not extend to your Central Provident Fund savings.
CPF money is ring-fenced by the CPF Act and sits outside your general estate no matter what your will says. It goes wherever you named on your CPF nomination form, filed online through the CPF Board's own system — and if you never filed one, the balance goes to the Public Trustee's Office for distribution under intestacy rules, even if your will explicitly says otherwise. Expats on Employment Passes who have built up six-figure CPF balances over a decade in Singapore routinely find out about this the hard way, through their families. File the nomination the same week you open the account, not after the first big salary credit lands.
Malaysia: Faraid runs next to your will, not underneath it
For Muslim residents, Malaysia applies Faraid, the Islamic law of fixed inheritance shares — a son typically receives double a daughter's share, and the shares are set by formula rather than by personal wish, regardless of what a will attempts to override. Non-Muslim expats fall instead under the Distribution Act 1958 for intestacy, but that only matters if there's no valid will; with one, Malaysian courts generally respect it.
Getting a foreign grant of probate recognised requires "resealing" it under the Probate and Administration Act 1959, a court process that commonly takes six to twelve months and can cost RM5,000–15,000 in legal fees once you add certified translations, affidavits and court appearances. That is a long wait for a family that just wants access to a Malaysia My Second Home property or a local bank account. A short, Malaysia-specific will covering only local assets skips the resealing step entirely, because the local court is dealing with a Malaysian document from the start rather than authenticating one from abroad.
Japan: the koseki system was never built with you in it
Japan's family registry, the koseki, tracks births, marriages, deaths and inheritance for Japanese nationals — foreign residents, even permanent residency holders, simply aren't in it. Under Article 36 of the Act on General Rules for Application of Laws, succession generally follows the deceased's national law rather than Japanese law, which sounds reassuring until a Japanese bank or the Legal Affairs Bureau asks for an apostilled, professionally translated grant of probate from your home country before releasing a single yen. That document chain can easily take a year to assemble from overseas, especially if the country of origin uses a slower probate court.
Inheritance tax adds a second layer that catches long-stayers off guard. A foreign resident who has lived in Japan for less than ten of the past fifteen years is only taxed on Japan-situated assets — the Tokyo apartment, the yen savings account. Cross that ten-year threshold, though, and the National Tax Agency treats inherited worldwide assets as taxable, turning a single Tokyo studio into the trigger for a global tax filing. The basic exemption is calculated as ¥30 million plus ¥6 million per statutory heir, which sounds generous until Tokyo property values are factored in.
Vietnam: you can inherit the value, never the land itself
Vietnam will hand you the money. It will never hand you the deed.
All land in Vietnam is owned by the state; what residents and businesses hold is a land-use right, not a freehold title, and foreigners are not on the list of parties eligible to hold one. When a foreign heir inherits land-use rights — say, from a Vietnamese spouse who owned the residential plot the family house sits on — Article 186 of the 2013 Land Law does not let the foreigner register the right in their own name.
Instead, the heir has to transfer the right to someone legally entitled to hold it, typically a Vietnamese relative, or sell it and keep the cash. Residential land plots handled this way commonly change hands for VND 500 million to 2 billion depending on province, and the transfer has to happen within a set administrative window after the grant of inheritance is recognised. Foreign-owned condos are a partial exception, capped at 30% of units per building under the 2014 Housing Law, but even those come with a 50-year ownership term (renewable once) rather than the indefinite title a Vietnamese buyer would get.
What actually protects your family
None of this means you need five separate law firms on retainer. It means treating each jurisdiction where you hold a condo, a bank account or a CPF-style pension as its own small estate, with its own short local will that names local assets only and doesn't contradict whatever will covers everything back home.
- Draft a local will for any Asian jurisdiction where you own property, hold a provident-fund account, or run a business — Thailand, Singapore, Malaysia, Japan and Vietnam each recognise a locally executed will faster than a foreign one.
- File beneficiary nominations directly with the institution wherever the law allows it — CPF in Singapore is the clearest example, and it overrides your will completely.
- Keep certified translations and, where required, apostilles of your home-country documents ready in advance rather than after the fact, since courts in Japan and Malaysia routinely demand them before releasing anything.
- Accept that land-adjacent assets in Thailand and Vietnam are never fully yours to leave behind in the way a house back home would be — plan for the forced-sale timeline, not around it.
Get the local paperwork done while you're still the one holding the pen. The alternative is a family member, grieving and thousands of miles away, learning Land Office procedure in a language they don't speak.