For executors and beneficiaries based overseas, we prepare High Court applications for a Hong Kong grant of probate (with a will) or letters of administration (without one), liaise directly with banks and insurers, and administer the full range of Hong Kong assets: company shares, bank accounts, insurance policies, property. We file in person at the Probate Registry and keep you informed at every step with clear written updates.
We help individuals – executors or beneficiaries – to navigate international probates with assets in Hong Kong. Our team of lawyers knows how to handle projects involving multiple jurisdictions. We pave the way and remove hurddles for a smooth rolling of your application for grant of probate in Hong Kong. The Probate Registry has a reputation to be difficult, however we’ve always successfully established our clients rights before them.
We speak Cantonese, English and French. We’ll help you sort out the probate in Hong Kong from wherever you are.
We arrange in-person filings of applications and answers to requisitions (if any) – on your behalf.
We analyse, clarify and plan for a smooth application with the Probate Registry of the High Court of Hong Kong.
We prepare affirmations, applications, declarations & foms for in-person filing and follow-up.
We help executors and administrators to fulfil smoothly their duties to pay for the estate’s debts and distribute the net assets to the beneficiaries of the Hong Kong estate.
Supporting families across civil-law and common-law systems, we align estates with Hong Kong probate standards, and handle filings, liaison, and paperwork end-to-end.
Since 2016, we’ve been helping individuals and corporations navigating international challenges with a steady-hand.
Our highly qualified team of Solicitors is fluent in different legal systems and cultures.
Our values: Clear, Forward-thinking and Effective.
Six areas of Hong Kong law that come up in every international probate mandate. This is where legal detail meets practical coordination.
When a grant of probate or letters of administration has been obtained abroad, Hong Kong may recognise it by resealing rather than requiring a fresh application. This is the practical shortcut for many cross-border estates.
The framework sits in Part V of the Probate and Administration Ordinance (Cap. 10). Section 48 defines the concept of a “designated country or place”, and section 49 sets out the mechanics: the foreign grant is produced to the Hong Kong court, a copy is deposited, and the grant is sealed with the court’s seal. Once sealed, the foreign grant has the same force in Hong Kong as if granted here.
For estates of persons who died on or after 11 February 2006, the resealing application under section 49 must include a schedule of Hong Kong assets exhibited under s.49(3). Any inaccuracy that comes to light before sealing must be corrected by a further schedule under s.49(5); any inaccuracy discovered after sealing must be reported by the executor or administrator.
Within one month of receiving the application, the Registrar must provide the Commissioner of Inland Revenue with the information the Commissioner requires for the purposes of the Inland Revenue Ordinance (Cap. 112).
Designated jurisdictions are Commonwealth-focused. The list has historically included the United Kingdom (England and Wales, Scotland, Northern Ireland), Australia, New Zealand, Singapore, Malaysia and a number of other Commonwealth jurisdictions. Mainland China is not a designated country for resealing purposes, so estates with Mainland involvement generally need a separate approach.
When the foreign jurisdiction is not designated, or when the deceased was domiciled outside Hong Kong under conditions that make resealing awkward, a fresh Hong Kong grant is the alternative. See our detailed guide to the Non-Contentious Probate Rules (Cap. 10A) for the fresh application process and to our Cap. 10 substantive guide for the underlying framework.
Executors and beneficiaries often ask whether a will made abroad, in a form very different from a typical Hong Kong will, can be admitted to probate in Hong Kong. The answer, in most cases, is yes, provided the will satisfies one of the formal validity tests set out in the Wills Ordinance (Cap. 30).
Under section 24 Cap. 30, a will is formally valid in Hong Kong if its execution complies with the internal law of any of the following:
This is the classic Hague-Convention-style test and it accommodates a wide range of foreign forms. A holograph French will, for instance, can be formally valid in Hong Kong if it satisfies French formal requirements. A will executed in the United States before a notary can be formally valid if it satisfies the law of the state of execution.
Cap. 30 s.24 addresses formal execution. Separate questions arise on the testator capacity, on the construction of the will, and on which country substantive succession law governs a specific asset. Our guide to wills in Hong Kong covers the domestic Hong Kong angle; the analysis for foreign wills also draws on the Wills (Miscellaneous Provisions) Ordinance (Cap. 596) and general private international law.
The starting question in every international probate matter is who died where, and where the assets sit. The two most common patterns are set out below.
A person domiciled abroad dies leaving Hong Kong bank accounts, listed securities, property or MPF entitlements. The Hong Kong court has jurisdiction over the Hong Kong assets, but not over assets outside Hong Kong (section 24A Cap. 10).
The typical route is either resealing the foreign grant (if the jurisdiction is designated) or a fresh Hong Kong grant. We assess which route is faster and cheaper for the estate.
A Hong Kong-domiciled person dies with assets in the Mainland, Singapore, the United Kingdom, France, the United States or elsewhere. The Hong Kong grant does not, by itself, extend abroad.
Foreign probate steps are usually required in each relevant jurisdiction. We act as Hong Kong counsel and coordinate with local counsel where you have them, or through our international network where you do not.
Estates spanning Hong Kong and Mainland China are increasingly common and are also the most misunderstood. Two points are usually the source of surprise.
First, resealing is not available. Mainland China is not a designated country under section 48 Cap. 10, so a Mainland grant cannot be resealed in Hong Kong under Part V, and vice versa. Estates with assets on both sides therefore typically require parallel probate applications, one in each jurisdiction, with the sequencing decided case by case.
Second, the reciprocal arrangements do not cover succession as such. The Mainland Judgments (Reciprocal Enforcement) Ordinance (Cap. 645), effective 29 January 2024, provides for reciprocal recognition of civil and commercial judgments between the two courts, but non-judicial proceedings are excluded. The Matrimonial and Family Cases arrangement (Cap. 639, effective 15 February 2022) covers divorce, custody and maintenance, but not succession or probate. In practical terms, estate matters continue to move through parallel probate applications and, on the tax side, through the Hong Kong to Mainland double taxation arrangement.
This section reflects the general position on cross-border succession between Hong Kong and Mainland China based on primary sources. Specific mandates may involve additional considerations, in particular where PRC succession law applies to non-HK assets, or where the deceased domicile is in dispute. Slotine tax practice can support the treaty relief side through the Certificate of Resident Status.
An international probate mandate is rarely a single-jurisdiction matter. We work either alongside your existing family lawyer abroad, or with a lawyer we bring in through our international network. Either way, our role in Hong Kong stays clear: we are the Hong Kong counsel of record, we prepare the Hong Kong filings and we deal with the Hong Kong asset holders.
Where the foreign law affects the Hong Kong application, we prepare affidavits or affirmations of foreign law, or arrange for them to be sworn by counsel abroad. Where the foreign court needs a Hong Kong element (a certified copy of a Hong Kong grant, a Hong Kong law affidavit), we assist on that side too.
The point of doing this properly is to avoid inconsistent positions across jurisdictions, to sequence the applications so nothing waits on itself, and to give the family a single point of contact for the Hong Kong side.
Hong Kong abolished estate duty in 2006. That does not mean cross-border estates escape all tax questions. Several foreign jurisdictions retain a form of inheritance or estate tax: the United Kingdom Inheritance Tax, the French droits de succession, the United States federal estate tax. Whether these apply to Hong Kong assets depends on the deceased’s domicile, on the location of the asset and on the treaty position, and the analysis is best done at the same time as the probate work rather than after.
On the Hong Kong side, if the estate continues to generate income after death, questions arise on the Certificate of Resident Status for treaty relief and on the interaction with Hong Kong’s foreign-sourced income exemption regime. If the deceased held assets through an investment vehicle, the interaction with the family office regime may be relevant.
Slotine’s tax practice runs alongside the international probate work. See our tax practice-area for the full picture.
Cross-border by focus
We act as Hong Kong counsel of record for foreign executors and internationally mobile families, and coordinate with your advisers in other jurisdictions so nothing falls between two systems.
English and French
We advise in English and French and are used to working with clients and beneficiaries across time zones.
End to end
From resealing a foreign grant or obtaining a fresh Hong Kong grant, through calling in assets, to distribution, we handle the Hong Kong side of the estate.
Clear engagement
We start with an assessment of your matter, then give you a clear fee proposal, fixed where the scope allows, before any work begins.
Our international probate practice sits alongside a set of detailed guides that cover the Hong Kong domestic angles in depth. For the procedural detail of a Hong Kong grant application, the Cap. 10A rules, caveats or letters of administration, please refer to the guides below.
Brillant firm! Very professional, and the quality of work is exceptional.
Slotine has been our trusted legal partner for several years.
Their business-oriented approach to contracts has played a key role in successfully negotiating agreements with multinational clients and securing our trademarks. The team brings solid legal expertise combined with an international mindset that is particularly valuable in cross-border matters.
Professional, responsive, and a real asset in our development.
I reached out to Slotine to help for legal advice and preparation of some documents related to a matter for my work. Out of the firms I contacted, they were the most proactive and understanding of the matter. They helped me brainstorm on the commercial details before taking care of the legal aspects. Results included simple yet strong legal documents that all parties can understand. Would recommend!
Navigating the legal landscape in Hong Kong can sometimes be daunting, but the team at Slotine – Hong Kong Law Firm is always very helpful. I chose Slotine – Hong Kong Law after researching various law firms and was impressed by their reputation for excellence and client-centered approach. From our initial consultation, it was clear that they prioritised understanding my specific situation and needs.
I highly recommend their services to anyone in need of skilled legal representation in Hong Kong!
I’ve worked with Maëva law firm in few occasions. Excellent experience, extremely professional, tailor made advices to structure deals and agreements. I highly recommend.
Thank you to Jessica, Mathilde and Maëva for your exceptional service in assisting me to draft a Will. I had previously spoken with several firms in Canada, Hong Kong, China and France, but none of them had the experience or ability to advise on multi-jurisdictional, cross-border Wills. From our first discussion I knew you were the right firm to work with. I appreciate your high level of engagement, responsiveness and insightful legal counsel in creating a solution that has given me great peace of mind. Thank you!
Choose a Suite that matches the simplicity or complexity of your estate in terms of administration, beneficiaries and assets in Hong Kong.
Ideal for single-asset estates to be administered by the spouse or one child.
Ideal for complex, multi-jurisdiction estates needing end-to-end Hong Kong handling and white-glove support.
About the authors Written by Jessica Lau · Founder and Solicitor at Slotine. Maeva leads the firm's cross-border probate and estate practice. The Non-Contentious Probate Rules, Cap. 10A, are the…
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