Estate Planning for NRIs with Indian Assets: One Global Will or a Separate Indian Will, and How Succession Actually Works

Your father in Pune held a flat, two NRO fixed deposits, and a demat account with Infosys and HDFC Bank shares. You live in London with a house in Surrey, a workplace pension, an ISA, and a US brokerage account holding Apple and a Vanguard S&P 500 ETF. The question that should keep you up at night is not how much inheritance tax your heirs pay in India, because India charges nothing on inheritance. It is whether your one neatly drafted English will can actually move the Pune flat into your daughter's name, and whether anyone has noticed that the US ETF carries a 40% estate-tax exposure above a USD 60,000 line that no treaty relieves.

Estate planning for an NRI is not one problem. It is three jurisdictions colliding: the country whose law governs each asset, the country where each asset physically sits, and the country where you are tax-resident when you die. India makes the first two simple in principle and slow in practice, and it adds a layer most NRIs never think about, that succession of your Indian assets is decided by your religion-based personal law. The foreign side adds the tax sting India never had.

The 30-second answer: For most NRIs with assets in more than one country, make a separate Indian will limited to Indian assets, alongside a separate foreign will, each with a clause stating it does not revoke the other. Immovable property in India is governed by Indian succession law (lex situs) regardless of residence, and intestate succession follows your religion-based personal law: the Hindu Succession Act, 1956 for Hindus, Sikhs, Jains, and Buddhists, Muslim personal law for Muslims, the Indian Succession Act, 1925 for Christians and Parsis. A will needs two attesting witnesses under Section 63; registration is optional but advisable; and after the Repealing and Amending Act, 2025 omitted Section 213 on December 20, 2025, probate is no longer compulsory anywhere, including for Mumbai or Chennai property. A nominee is a trustee, not the owner (Shakti Yezdani, 2023), so the will prevails. India has no inheritance tax, but US estate tax (USD 60,000 exemption, up to 40% on US-situs assets) and UK inheritance tax (40% above 325,000 pounds for long-term residents) can apply.

This guide is part of our NRI investments series. For the tax side of inheriting and the cross-border estate-tax detail, pair it with inheritance and estate tax for NRIs.

A separate Indian will beats one global will, and the reason is administration, not validity

The instinct is to write one tidy will covering everything. The law allows it; a properly executed will can dispose of assets anywhere. The reason it fails NRIs is not validity, it is administration, and the cost lands on the people you leave behind as frozen accounts and lost months.

When you die, the will has to be proved in each place you hold assets, and each country runs its own process. A will drafted to English or American conventions, with foreign witnesses and references to foreign law, is unfamiliar to an Indian sub-registrar, bank, and court. Where the original sits with a foreign probate registry, your Indian executor often cannot move until the foreign grant issues and is relied upon in India. That sequencing is the trap: the Pune flat sits frozen behind a London queue for the better part of a year, because the Indian institutions want to see a process they recognise before they release anything.

The principle underneath all of this is lex situs: immovable property is governed by the law of the country where it sits. Your Pune flat is governed by Indian succession law no matter what your English will says or where you are domiciled. Movable assets are more flexible and are often governed by the law of the deceased's domicile, but Indian banks and depositories in practice want an Indian process for Indian-held movables too. So even with one global will, your Indian assets run through the Indian system regardless; a single will just makes the Indian step wait in line behind the foreign one.

A separate Indian will, limited to Indian assets, breaks that dependency. It is drafted in Indian form, witnessed the way Indian courts expect, ideally registered in India, and names an executor who can act on the ground. The moment the death certificate is available, your Indian executor begins, in parallel with whatever is happening in the UK or US, rather than behind it. Most cross-border practitioners advise this two-will (or multi-will) structure for NRIs with substantial assets in two or more countries.

There is one rule you cannot get wrong, and it is where DIY estate plans die. A standard will opens by revoking all previous wills. If your later UK will carries that boilerplate, it can wipe out your earlier Indian will, and you die effectively intestate in India over the exact asset you most wanted controlled. Each will must state plainly that it deals only with assets in that specific country and does not revoke any other will, naming the other by date. Have both drafted in coordination, and if you re-do one later, re-do or expressly preserve the other.

The honest caveat: if your only foreign assets are minor and almost everything sits in India, or the reverse, a single carefully drafted will is enough, and a second will is just cost and coordination risk. The two-will structure earns its keep when you hold real money in two or more systems that each demand their own proof.

In India your religion decides who inherits, not your passport

Two separate questions hide inside "what law applies." The first is which country's law. The second, peculiar to India, is which community's personal law.

On the first, Indian immovable property is always governed by Indian law. This is not a FEMA point and not an income-tax point; it flows from succession law and lex situs. An NRI, a PIO, or an OCI holder has exactly the same right to inherit Indian property as a resident, and the same Indian law applies. Foreign citizenship does not move your Pune flat out of the Indian system, and your foreign will does not override Indian succession rules for it.

On the second, and this is the part that blindsides NRIs raised on the idea of a single secular code: in India, your religion determines how your assets pass if you die without a will. Succession is governed by religion-based personal law, not by residence or nationality.

Hindus, Sikhs, Jains, and Buddhists are governed by the Hindu Succession Act, 1956. On intestacy, Class I heirs, broadly the spouse, children, and mother, inherit simultaneously in equal shares for self-acquired property. The 2005 amendment gave daughters equal coparcenary rights in ancestral property, so the old village assumption that "the flat stays in the son's name" has no legal basis. Muslims are governed by their personal law of inheritance, under which fixed shares (the faraid) go to specified heirs, and crucially the freedom to will is capped: broadly no more than one-third of the estate can be bequeathed by will without the consent of the other heirs. Christians and Parsis are governed by the relevant parts of the Indian Succession Act, 1925, each with its own intestacy shares.

This matters to your will in two ways. A will lets you override most of these defaults and direct your Indian assets where you want, within the limits your personal law allows, the Muslim one-third restriction being the sharpest. And if you die without a will, the law that carves up your estate is fixed by your religion at death, and the shares may not be what you assumed. An NRI who has spent twenty years abroad and pictured everything going to a spouse can be surprised that the Hindu Succession Act splits self-acquired property four ways across spouse, two children, and a surviving mother.

Intestacy is also operationally brutal. Without a will, heirs typically need a succession certificate for bank deposits and shares, and a legal heir certificate plus mutation to move property titles, court and revenue-office processes slower and far more open to dispute than a clean will, with no one coordinating across jurisdictions. There is a hard cash consequence too: your NRO account will not release funds for repatriation until succession is proven, so an intestate death can lock heirs out of the very money they need to administer the estate. For the title-transfer machinery, see buying property in India as an NRI.

The December 2025 probate repeal just made your Indian will faster to enforce

A valid Indian will is simpler to create than most people fear, and as of late 2025 it is meaningfully easier to enforce than the old guides say.

Execution. Under Section 63 of the Indian Succession Act, 1925, the testator signs the will and it is attested by two or more witnesses, each of whom has seen the testator sign and signs in the testator's presence. That is the whole core requirement. There is no compulsory format, no stamp duty on a will, and no need for a lawyer to draft it, although a badly drafted will is a gift to anyone who wants to contest it. A witness should not be a beneficiary, and for an NRI it helps if at least one witness can realistically be located and called years later. A brief doctor's note confirming sound mind at signing is cheap insurance against a "he wasn't of sound mind" challenge from a disappointed heir.

Registration. Registering the will at the Sub-Registrar's office is optional, and an unregistered will is fully valid. But registration creates a strong presumption of genuineness, places a copy in public records so the original cannot simply vanish, and makes a tampering allegation far harder to sustain. For an NRI, whose heirs may be challenged precisely because the testator lived abroad and the witnesses are scattered, registration is usually worth the modest effort. You can register on a visit to India, and many NRIs do it on the same trip they sign. Registration does not lock the will; you can revoke or replace a registered will with a later will, subject to the non-revocation drafting point above.

Probate, and this is the part that changed. Older guidance, including earlier drafts of this one, told Hindu NRIs that a flat in Mumbai or Chennai would need probate because of Section 213 of the Indian Succession Act, which made probate compulsory for wills made by Hindus, Sikhs, Jains, Buddhists, and Parsis within the original civil jurisdiction of the Bombay, Calcutta, or Madras High Courts or relating to immovable property there. That is no longer the law. The Repealing and Amending Act, 2025, which received Presidential assent on December 20, 2025, omitted Section 213 entirely, removing the religion-based, city-based probate mandate that Parliament itself called discriminatory. Probate is now optional across the whole country: a Hindu NRI leaving a flat in Mumbai is, in law, in the same position as one leaving a flat in Pune. The repeal is prospective, with a savings clause so probates already granted are untouched.

What has not changed is institutional caution. Banks, depositories, registrars, and buyers may still ask for probate or a succession certificate before handing over a large asset, because a court order is what protects them from a later claim. So treat the repeal as removing a legal floor, not as a promise no one will ask: budget for the possibility that a bank or buyer insists, while knowing you can no longer be forced into it just because the property is in a presidency town. Where it is taken, probate is filed before the court with jurisdiction over where the asset sits and runs anywhere from a few months to well over a year depending on the court and whether anyone objects.

An executor abroad is fine in law, and a co-executor in India is what makes it work

An executor collects the assets, pays the debts, and distributes to the beneficiaries. NRIs routinely ask whether the executor must live in India. The answer is no: a testator can name any competent adult, resident or non-resident, and the law imposes no residency requirement. An NRI can be an executor.

The constraint is logistics, not legality. An executor in Toronto can run an Indian estate, but they will be dealing with Indian banks, registrars, and courts from abroad, which is slow and document-heavy. So the sensible structure for many NRIs is to name a co-executor or trusted person resident in India, so someone can physically attend the sub-registrar, the bank, and the court without flying in for every signature. A professional executor (a lawyer or trust company) is also an option.

Whoever you choose, equip them, and note one limit precisely: a Power of Attorney dies with you. A POA is useful for managing affairs during your lifetime, and the rules are in Power of Attorney for NRI banking and property, but it does not survive to administer the estate. The will and the executor do the post-death work; the POA only helps before death. Confusing the two is a common and expensive mistake.

The single most useful thing you can do for any executor is leave an asset register: a current list of every Indian account, demat, property, deposit, and policy, with account numbers, the holding institution, the nominee on each, and where the documents sit. Indian institutions do not talk to each other, and an executor who does not know an account exists cannot claim it. Plenty of NRI estates quietly leak value because the heirs never found the deposit.

A nominee is a trustee, never the owner, and the 2025 banking law makes getting nominations right easier

This is the most common and most expensive misunderstanding in NRI estate planning, so be exact about it. When you open a bank account, a demat account, an FCNR or NRO deposit, a mutual fund folio, or a life insurance policy, you name a nominee. NRIs, and Indians generally, assume the nominee becomes the owner on death. They do not. A nominee is a trustee or custodian who receives the asset so the institution has a clear, discharged party to pay, and who then holds it for the people legally entitled under the will or, failing a will, under succession law.

The Supreme Court settled this in Shakti Yezdani v. Jayanand Jayant Salgaonkar, decided in December 2023. The deceased had both a registered will and separate nominations for securities and deposits under Section 109A of the Companies Act and Section 9 of the Depositories Act; after his death the nominees claimed full ownership while the will-beneficiaries claimed under the will. The Court held that nomination is administrative, not a third mode of succession, that a nominee acquires no beneficial ownership, and that succession is governed by the will or, failing that, by the applicable succession law. This sits on decades of consistent authority going back to Sarbati Devi v. Usha Devi (1984) on life insurance, with one narrow statutory exception: a "beneficial nominee" under Section 39(7) of the Insurance Act can in some cases keep policy proceeds, an exception even High Courts read narrowly against defeating heirs.

The reform that genuinely helps you came into force on November 1, 2025: the Banking Laws (Amendment) Act, 2025 now lets you nominate up to four people on a bank deposit, locker, or safe-custody article, either simultaneously (each with a percentage share adding to 100, for deposits) or successively (the next nominee operative only on the death of the one above, the only option for lockers). For an NRI with heirs spread across countries, simultaneous nomination in the shares your will sets out makes collection and entitlement line up from the start, instead of routing everything through one nominee who then has to distribute.

So three rules follow. The will overrides the nomination: if your demat names your brother but your will leaves the shares to your daughter, the daughter is entitled, and the brother merely collects and holds for her. Align nominations with the will anyway, because mismatches create exactly the dispute Shakti Yezdani arose from, and the four-nominee facility now lets you match a multi-heir will on the account itself. And keep nominations current: a stale nominee, an ex-spouse, a deceased parent, forces the heir to prove entitlement the hard way. For the account-level detail, see NRI account nomination and succession.

A trust earns its keep only when continuity, a dependant, or probate-avoidance is concrete

For most NRIs, a registered will with aligned nominations is enough, and a trust is over-engineering. A private family trust earns its place only in specific situations. Because the assets sit in the trust rather than your personal name, they do not pass through your estate on death and do not need probate, transferring control to the next generation without the court process a will can involve. That continuity and privacy is the main draw. Trusts also help where a dependant cannot manage assets (a minor, a parent needing lifelong support, a beneficiary with special needs), where you want to keep a family business or property intact across generations, or where you want protection against future disputes among heirs.

The structure drives the tax. A revocable trust, where you can take the assets back, gives you control but the income is clubbed back to you under Section 61 and taxed at your rate, so it offers little tax advantage during your life. An irrevocable specific trust, with defined beneficiary shares, is generally the most efficient: income is taxed in the beneficiaries' hands at their slab rates under Section 161. A discretionary trust, where trustees decide who gets what, is taxed at the maximum marginal rate under Section 164, the price of that flexibility.

For NRIs there is an extra layer: FEMA governs what a trust with NRI beneficiaries can hold and how proceeds are repatriated. Inherited or trust-held property can generally be sold and the proceeds repatriated up to USD 1 million per financial year from an NRO account with Form 15CA and 15CB certification, but the structure must be set up with FEMA in mind from the start; see the NRO repatriation process. A trust is a real commitment in cost and administration, so use it where the continuity, dependant-protection, or probate-avoidance benefit is concrete, not as a reflexive upgrade over a will.

The estate taxes India never warned you about live in the US and the UK

Here is the part that catches NRIs flat. India abolished estate duty in 1985 and has had no inheritance tax and no estate tax since. That trains you to treat death as a tax-free event. It is not, once your estate touches the US or the UK, and the numbers are large.

US estate tax is the more clear-cut and the more dangerous because the threshold is so low. If you own US-situs assets at death and you are not a US citizen or US-domiciled, your estate faces US estate tax with an exemption of only USD 60,000, unchanged for 2026 because it was set in the 1970s and is not inflation-indexed, and rates up to 40% above it. US-situs assets include US-listed shares (Apple, Microsoft, Tesla, even held through a non-US broker), US-domiciled ETFs and mutual funds, and US real estate. An ETF's domicile of registration, not yours, is what counts. There is no US-India estate tax treaty, so the income-tax DTAA gives you nothing, and India offers no credit because it levies no estate tax to credit against. The standard fix is to hold US-market exposure through non-US-domiciled funds, typically Ireland-domiciled UCITS ETFs, which are not US-situs for estate-tax purposes, so the same S&P 500 exposure sits outside the 40% net. That is a decision you make while alive; an executor cannot unwind it after death.

Put a number on it. Suppose your US brokerage holds USD 220,000 split between directly held US shares and a US-domiciled S&P 500 ETF. On death, the first USD 60,000 is exempt and roughly USD 160,000 is exposed at up to 40%, a potential USD 64,000 US estate-tax bill on assets India would have passed tax-free. Had the same S&P 500 exposure been held through an Ireland-domiciled UCITS ETF and the directly held US shares trimmed below the line, the US-situs estate would fall under USD 60,000 and the bill would be close to zero. The difference, about USD 64,000, is the price of holding the wrong wrapper, and it is fixable only before death.

UK inheritance tax reformed on April 6, 2025, replacing the old domicile-based test with a residence-based one. Once you have been UK tax-resident for 10 of the last 20 tax years, you are a long-term resident, and your worldwide estate falls within IHT at 40% above the 325,000 pound nil-rate band, which is now frozen until April 2031. The exposure does not end when you leave: there is a tail of three to ten years, scaling with how long you were resident (three years if you were resident for 10 to 13 of the last 20, rising to ten years for long-settled residents), during which your global estate stays in the net. So a long-settled Indian professional in London can have her Pune flat and Indian shares pulled into UK IHT, not because India taxes them, but because the UK does.

There is a genuine, and genuinely useful, shield: the 1956 UK-India estate duty double taxation convention. It provides that UK IHT is not charged on non-UK assets of someone who dies domiciled in India, and it does so regardless of whether UK domestic rules would deem the person UK-domiciled. Critically, the April 2025 reforms did not touch it: the pre-1975 estate-duty treaties with India, Pakistan, France, and Italy contain no deemed-domicile override, and HMRC has confirmed that domicile survives for wills, succession, situs, and double-tax relief even though it no longer drives IHT scope. So an Indian-domiciled long-term UK resident can still argue the treaty excludes her Indian estate from UK IHT. The catch is that this turns on her being Indian-domiciled under common-law tests, which a long UK residence makes harder to hold, and the interaction of the old treaty with the new residence regime is untested in practice. The honest position: the treaty likely still protects Indian assets for the genuinely Indian-domiciled, but this is exactly the question for a specialist UK-India estate adviser, not to assume. For the residence mechanics, see residency and RNOR rules for NRIs, and for the tax when an heir later sells, selling inherited property and NRI tax.

The other two phase-1 countries are easier. The UAE levies no estate or inheritance tax, so a Dubai-based NRI's only death exposure is on any US-situs or UK-situs assets they hold; the Indian estate passes clean. Canada has no estate tax either, but it runs a deemed-disposition rule: on death you are treated as having sold your capital property at fair market value, and the resulting capital gain is taxed on your final return. That is a capital-gains charge, not an estate tax, but it can still bite appreciated Indian shares or property for a Canadian-resident NRI, and it is the cross-border quirk Canada-based readers most often miss.

How the two-will structure plays out, and what dying intestate actually costs

The two-will logic is easiest to see on a real estate. Take Anita, a Hindu NRI who has lived in London for 14 years and is now a long-term UK resident. In India she holds a Pune flat worth Rs 1,80,00,000, an NRO fixed deposit of Rs 40,00,000, and a demat account worth Rs 30,00,000, a total of Rs 2,50,00,000. In the UK she has a Surrey house, an ISA, and a pension; in the US, a brokerage account holding Apple shares and a US-domiciled S&P 500 ETF worth USD 220,000. She wants the flat and shares to her daughter, the NRO deposit to her mother, and the UK and US assets split between her daughter and her brother.

Good planning is an Indian will covering only the Pune flat, NRO deposit, and demat, with a clause that it does not revoke her UK will, and a UK will covering the rest with a matching non-revocation clause. She signs the Indian will in Pune before two witnesses (neither a beneficiary), with a doctor's capacity note, and registers it. She names her brother in London and a cousin in Pune as co-executors, so the cousin can attend the sub-registrar and bank in person, and updates the demat and NRO nominees to her daughter and mother using the new simultaneous-nomination facility to match the will. The whole Rs 2,50,00,000 passes with no Indian inheritance tax, and because Section 213 is gone, no presidency-town probate mandate slows the flat even if it sat in Mumbai.

The real money is on the foreign side. Her USD 220,000 US account is US-situs; above the USD 60,000 exemption, roughly USD 160,000 is exposed at up to 40%, a potential USD 64,000 bill India would never have charged. She moves the S&P 500 exposure into an Ireland-domiciled UCITS ETF and trims the directly held US shares below the line, shrinking the exposure toward zero, a fix possible only while she is alive. On UK IHT, as a long-term resident her worldwide estate is in the net at 40% above 325,000 pounds, and whether the 1956 treaty shields the Indian Rs 2,50,00,000 turns on her staying Indian-domiciled, which she takes to a specialist. The Indian side is clean and fast; the foreign tax exposure is where planning saved real money, and it had to be done before death.

Now the counterfactual that shows why any will beats none. Rajesh, a Hindu NRI in Toronto, dies suddenly with no will, leaving a Bengaluru flat worth Rs 2,00,00,000, an NRO deposit of Rs 25,00,000, and shares worth Rs 15,00,000, a total of Rs 2,40,00,000, survived by his wife, son, daughter, and mother. The Hindu Succession Act, 1956 governs, and his four Class I heirs each take one-fourth, Rs 60,00,000 apiece, the daughter equal to the son. For the deposit and shares the heirs need a succession certificate (six months to over a year); for the flat, a legal heir certificate and mutation into four names jointly. With heirs split between Canada and India, every document needs notarisation and apostille, and the NRO account stays frozen for repatriation until succession is proven.

None of this attracts Indian inheritance tax, because India has none. But the flat is now jointly owned by four people across two countries, and any later sale needs all four to agree, sign, and clear TDS under Section 195. Had Rajesh left a simple registered Indian will, his executor could have acted directly, the distribution would have matched his wishes rather than the Act's mechanical quarters, and the family would have saved a year of proceedings and the friction of four-way joint ownership. Intestacy cost his heirs no tax. It cost them time, control, and the distribution he would actually have chosen.

How the will decision differs by where you live

Where you live	Death tax on your worldwide / Indian estate	The thing to get right
UAE	None locally; only US-situs or UK-situs assets exposed	Separate Indian will; watch any US shares or ETFs
USA	US estate tax on worldwide estate, but USD 60k exemption is for non-residents; US-situs always caught	Separate Indian will; whether you are US-domiciled changes everything, take advice
UK (long-term resident)	IHT at 40% on worldwide estate above 325,000 pounds, 3 to 10 year tail	Separate Indian will; test the 1956 treaty and your domicile with a specialist
Canada	No estate tax, but deemed disposition taxes gains at death	Separate Indian will; plan the capital-gains hit on appreciated Indian assets

Edge cases worth flagging in the will itself

Agricultural land. An NRI can usually inherit agricultural land, plantation property, or a farmhouse even though they cannot ordinarily buy it under FEMA. The succession route is open; the purchase route is not. Selling inherited agricultural land carries its own FEMA and buyer-eligibility constraints, so name it in the will and plan the eventual exit rather than leaving heirs to discover the restriction.

Muslim NRIs and testamentary limits. Under Muslim personal law the freedom to will is capped, broadly to one-third of the estate without the other heirs' consent, so a Muslim NRI's will cannot redirect the whole Indian estate the way a Hindu's can. Plan within that constraint from the start.

Joint holdings and survivorship. A jointly held Indian asset with survivorship may pass to the survivor by operation of the holding, but, as with nominations, that does not automatically settle beneficial ownership against the will. Coordinate joint holdings, nominations, and the will so they tell one story rather than three.

OCI, citizenship, and domicile. Holding an OCI card or foreign citizenship does not change your right to inherit Indian property or the Indian law that governs it; the planning is about the foreign overlay, not the Indian inheritance right. And after the UK's 2025 reforms, domicile and tax residence are separate tests: you can be UK-resident for IHT yet still Indian-domiciled for the 1956 treaty and for succession law, so do not let one answer the other.

The honest read

Estate planning for an NRI is two jobs, and most people do the first badly and skip the second entirely. The first is making sure your Indian assets reach the people you choose, quickly, without a year lost to courts and certificates. That is won with a separate Indian will, executed under Section 63, registered, with an executor who can act on the ground, nominations aligned to the will, and a clear asset register. The December 2025 repeal of Section 213 made it simpler still, because no city or religion now forces probate on you. None of it is expensive; it just has to be done before you need it, which is the part people defer until it is too late.

So commit to the recommendation: for the common case, an NRI with real assets in India and a second country, write the two-will structure, register the Indian will, and align your nominations. A single global will is justified only when one side is trivial, and a trust only when a dependant, business continuity, or probate-avoidance gives a concrete reason.

The second job is the one India never taught you, because India charges nothing on death. Your US-situs assets carry a 40% estate-tax exposure above a USD 60,000 line that no treaty relieves, and if you are a long-term UK resident your worldwide estate can fall within UK IHT at 40%, with only the contested 1956 treaty between the UK taxman and your Pune flat. The US exposure is the more fixable: move US-market exposure into non-US-domiciled funds while you are alive and it largely disappears. The UK position is genuinely unsettled after the 2025 reforms, so anyone with a substantial estate and a long UK residence should pay for specialist advice rather than rely on a guide, including this one.

If you do nothing else after reading this: write the separate Indian will, register it, align your nominations, and audit your US-situs holdings. Those four moves, made now, are worth more than any planning your heirs can attempt after you are gone.

Related guides

• Inheritance and estate tax for NRIs
• Selling inherited property and NRI tax
• NRI account nomination and succession
• Buying property in India as an NRI
• Building an India corpus as an NRI
• NRI retirement planning across two countries
• Power of Attorney for NRI banking and property
• Gift tax for NRIs in India
• NRE, NRO, and FCNR accounts explained
• The NRO repatriation process
• Residency and RNOR rules for NRIs
• All taxation guides
• All banking guides
• All investments guides

Disclaimers

This guide is general information for NRIs and not legal, tax, or estate-planning advice. Succession, wills, probate, FEMA, and cross-border estate tax are fact-specific and depend on your religion, domicile, residence, the location and nature of each asset, and the law in force when you act. Rules cited here, including the omission of Section 213 by the Repealing and Amending Act, 2025, the Banking Laws (Amendment) Act, 2025 nomination changes effective November 1, 2025, the UK inheritance tax residence test effective April 6, 2025, the status of the 1956 UK-India estate duty treaty after that reform, and US estate-tax thresholds, can change and are in some respects genuinely debated. The US estate-tax and UK IHT positions in particular should be confirmed with a qualified cross-border adviser before you act. Verify current law with a qualified solicitor or advocate, a chartered accountant, and a specialist estate-tax adviser in the relevant country before making or relying on any estate plan.