The Document Problem: What Your Family Won't Find If Something Happens to You
When my grandmother died in Bangalore, the paperwork didn't match. There were things in the will that couldn't be found, and things found that weren't in the will.
My mother and my aunt sorted it out. It took time, and it took patience with a system that works differently from the one my wife grew up with. India lets you leave your estate to whomever you choose. France, where my wife is from, reserves a fixed share for children.
I was there when she passed, and two things stayed with me. The first was ordinary: I am going to die too. The second was the contrast. She lived her whole life in one city, with her assets mostly in that city, and it was still hard to piece together. I have lived in four countries. If something happens to me, my children won't even know what they have.
Cross-Border Wealth Lives in Paper
A single-country household's finances can mostly be reconstructed from a bank login and last year's tax return. A cross-border household's can't. The record of what exists is spread across documents in several countries, several languages and several formats, and the most important of them were signed once and then put away.
In India: the sale deed and the khata or mutation record for property, the encumbrance certificate, property tax receipts, fixed deposit receipts for NRE, NRO and FCNR accounts, a PPF passbook, an EPF account number, the consolidated account statement for demat and mutual fund holdings, life insurance policies.
In Europe: a pension overview from each country you worked in (the Dutch one at mijnpensioenoverzicht.nl, the German Renteninformation, a Swiss pension fund certificate and your AHV account statement), employer equity plan documents, your tax returns, and the deeds and mortgage for wherever you live.
Your family can't ask for a document they don't know exists. What gets lost is the knowledge that the paper exists, and where it is.
A Nominee Is Not an Heir
Most Indian accounts and policies carry a nominee, and most families treat the nomination as the plan. Indian courts don't. The Supreme Court of India held in Sarbati Devi v. Usha Devi (1984) that the nominee of a life insurance policy receives the money but does not own it, and confirmed the same for shares and securities in Shakti Yezdani v. Jayanand Salgaonkar (2023). The nominee collects. The heirs under the will, or under succession law if there is no will, keep.
If the property is in Mumbai, Chennai or Kolkata, a will that covers it will generally need probate under the Indian Succession Act, 1925, before your heirs can deal with it. Elsewhere, banks and registrars may still ask for a succession certificate or a legal heir certificate. Either way, it takes months, and it runs through Indian courts in a language and a system your family in Europe may not know.
Two Legal Systems, One Estate
If you live in the EU, the EU Succession Regulation (No 650/2012) applies the law of the country you habitually live in at death to your whole estate, unless your will chooses the law of your nationality instead. Denmark and Ireland don't apply it. Switzerland has its own rules with a similar choice for foreign nationals. India applies its own logic: Indian law to Indian immovable property, wherever you live, and the law of your domicile to the rest.
So an Indian citizen living in Amsterdam with a flat in Bengaluru can have Dutch law claiming the whole estate and Indian law claiming the flat. A European certificate of succession means nothing to a sub-registrar in Bengaluru. Assume two systems will each take a piece, and write wills that know about each other: one where the property is, consistent with the one where you live, and neither revoking the other by accident.
The question to ask yourself
If you were unreachable tomorrow, could the person who would have to deal with this list every account, policy and property you hold, in every country, and find the document behind each one? If the answer depends on you being there to explain it, the plan is you.
Memory, Not Just Records
My grandmother's estate was hard because the record and the reality had drifted apart over a lifetime, in one city. A cross-border life drifts faster. Accounts go dormant, rules change in countries you no longer follow, documents sit in a drawer in a flat you sold.
What protects a family isn't a folder assembled in a rush after someone dies. It's a record kept current while the person who knows everything is still here to keep it. The everyday version of that problem is in the family CFO.
If something happened to you tomorrow, would your family know what you own in each country?
A blog post can tell you the rule. It can't tell you what it means for your accounts, your dates, your numbers. That's a conversation, not a search result.
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