Most people who move assume their existing will simply follows them, the way their passport does. It does not. A will is a legal instrument interpreted under the laws where it was made and applied to assets under the laws where those assets sit, and the moment your life spans South Africa and the UK, one document is being asked to do two jobs under two legal systems, two tax regimes and two probate processes.
Nothing in this guide is legal advice, and every structural decision described here belongs with an estate planning specialist: a solicitor or STEP-qualified practitioner in the UK, and a fiduciary specialist or attorney in South Africa. What this guide does is show you the map, because the families who arrive at those specialists knowing the terrain get better outcomes for less money.
Why one will is rarely enough
The standard answer for someone with assets in both countries is two wills: a South African will governing South African assets and a UK will governing UK assets, each drafted under its own jurisdiction's formalities, each explicitly limited in scope, and each acknowledging the other's existence.
The reasons are practical rather than pedantic. A single worldwide will can work, but it must then be processed in both countries' estate systems, translated into each system's requirements, and administered at the speed of the slower one. Two properly coordinated wills let each estate proceed in parallel under the system that understands it.
The word doing the heavy lifting is coordinated, which brings us to the trap.
The accidental revocation trap
Nearly every will begins with a revocation clause: "I revoke all wills and testamentary dispositions previously made by me." It is boilerplate, and it is the single most destructive sentence in cross-border estate planning, because a new UK will opening with those words revokes your South African will too, silently, without anyone realising until both documents are needed and only one is valid.
The fix is drafting, not vigilance: each will's revocation clause is limited to its own jurisdiction ("I revoke all previous wills insofar as they relate to my assets in the United Kingdom"), and each drafter is told the other will exists. Which means the practical rule for any South African in the UK is simple: never sign a will in either country without telling the drafter about the other country's will, and never let a well-meaning UK high-street will service near your affairs without that conversation happening first.
Two death taxes, two sets of rules
South African estate duty and UK inheritance tax are separate taxes that can both take an interest in the same estate, and they are built differently (both positions as of July 2026):
- South African estate duty applies at 20 percent on the dutiable estate up to R30 million and 25 percent above that, after an abatement of R3.5 million, with the unused portion of the abatement transferable between spouses.
- UK inheritance tax applies at 40 percent above the nil-rate band of £325,000, with a residence nil-rate band of up to £175,000 where a home passes to direct descendants, and transfers between spouses generally exempt.
- The UK's reach changed in April 2025. Inheritance tax scope now follows long-term residence rather than the old domicile concept: broadly, once someone has been UK resident long enough to be a long-term resident, their worldwide assets, including everything still in South Africa, come within the UK inheritance tax net. Exactly when that happens for you, and what it means for assets you left behind, is precisely the question to put to a UK estate specialist, because the answer now changes with your years in the UK rather than your intentions about where home is.
Relief against the same asset being taxed twice exists between the two countries under a long-standing estate duty convention [PETER/RICHELLE - VERIFY the SA-UK estate duty convention's current application before publish], but relying on it is planning's last resort, not its strategy.
The executor problem
A UK grant of probate has no force in South Africa. South African assets are administered through a separate process under the Master of the High Court, which appoints an executor under South African rules, and those rules do not simply accept whoever the UK will nominated. A UK-resident executor administering a South African estate faces practical hurdles around appointment, security and local representation, which is why South African wills commonly nominate a South African-based executor or professional fiduciary, and why the two-wills structure quietly solves a problem most families never knew they had: each estate gets an executor the local system will actually empower.
The mirror image applies. A South African executor cannot administer UK assets on South African authority; the UK estate needs its own grant.
Where the money side meets the planning side
Our lane in all of this is the one we know: when a South African estate pays out to UK-resident heirs, the proceeds cross the corridor through the inheritance transfer process, with the estate's paperwork, the heir's status, and where applicable the SARS non-resident confirmation letter determining the SARS route. For de-registered non-residents, inheritances up to R10 million do not require a Manual Letter of Compliance, while amounts above R10 million do, territory covered in our large transfers guide. The transfer itself runs at bank-beating rates with the bank's flat R250 SWIFT fee as the only transfer cost.
What we will not do is design the estate plan, and neither should any transfer provider. The families best served are the ones with a coordinated pair of specialists, one in each country, who have seen each other's documents.
[PETER VOICE - REVIEW REQUIRED] The inheritance transfers that run smoothly and the ones that run for a year share one difference, and it is never the money: it is whether the deceased's paperwork matched their life. Two coordinated wills, a South African executor for the South African estate, and the heir's tax status already confirmed with SARS, and the transfer is administration. One outdated worldwide will signed in 1998, and everyone involved learns more about the Master's office than they ever wished to. Sort it while it costs a drafting fee, not while your family pays for it in time. [END PETER VOICE]
Expecting or administering a South African inheritance?
We will map the SARS route and handle the transfer while your specialists handle the estate.
Talk to the team
Frequently asked questions
Do I need separate wills for South Africa and the UK?
Usually yes, if you hold assets in both countries: one will per jurisdiction, each limited to that country's assets and each drafted knowing the other exists. A single worldwide will can work but is administered at the speed of the slower system. Confirm the right structure for your estate with a specialist in each country.
Can a UK will cancel my South African will?
Yes, and it is the most common cross-border estate mistake. A standard revocation clause revoking "all previous wills" cancels the South African will unless it is expressly limited to UK assets. Never sign a will in either country without telling the drafter about the other.
Do South Africans in the UK pay UK inheritance tax on South African assets?
Potentially. Since April 2025, UK inheritance tax scope follows long-term residence, and once you qualify as a long-term UK resident your worldwide assets come within its net. When that point arrives for you is a question for a UK estate specialist.
Can my UK executor deal with my South African assets?
Not on UK authority. South African assets are administered through the Master of the High Court under South African rules, which is why South African wills commonly appoint a South African-based executor or professional fiduciary.
How does an inheritance from South Africa reach the UK?
Through the estate's normal administration and then a transfer under the applicable SARS route: de-registered non-residents can receive inheritances up to R10 million without a Manual Letter of Compliance, while larger amounts require one. The transfer leg is what WBForex handles.
