Probate laws 'vary according to jurisdiction'

Probate laws are not the same the world over and can vary greatly even between neighbouring countries - such as England and Scotland - and within the European Union (EU).

For this reason individuals with assets or property outside Britain may find they have to take account of regional variations when making a will, the Financial Times reveals.

While long-term plans are being made to reduce the divergence between EU member states, these are still some way off, meaning differing probate laws have the potential to cause unexpected problems.

If, for example, a Briton owned a house in France, despite the fact that their assets would be governed by British probate law, the property would almost certainly fall under the regulations of the country in which it is located.

Alexander Moseley, son of ex-Formula 1 boss Max Mosley, died earlier this year having not made a will, meaning his £1.6 million estate passes automatically to his parents. The wealthy family may own property abroad and as such, jurisdiction might be an important inheritance issue.