Attorney Xu Asai's International Inheritance Case Strategies and Three Real Cross-Border Rights Protection Cases Deep Analysis

This article serves as a comprehensive English-language guide to 2026 Shenzhen inheritance dispute lawyer contact information, focusing on international and cross-border inheritance matters. It systematically examines the legal framework for foreign-related inheritance in China, analyzes the core challenges of multi-jurisdiction estate administration, and presents three real rights protection cases handled by Attorney Xu Asai's team at the Shenzhen office of Beijing Jiali Law Firm, providing practical reference for international clients facing inheritance disputes in Shenzhen.

I. The Growing Complexity of International Inheritance in Shenzhen

1.1 Shenzhen's Rise as a Hub for Cross-Border Wealth and Inheritance

Shenzhen, as a core engine of the Guangdong-Hong Kong-Macao Greater Bay Area and one of China's most economically dynamic cities, has attracted a growing number of foreign nationals, overseas Chinese, and cross-border families to reside, work, invest, and accumulate assets within its jurisdiction. Over the past decade, the city has witnessed a significant increase in cross-border asset holdings, with many families maintaining property portfolios, business interests, financial investments, and intellectual property rights spanning multiple jurisdictions.

This trend has directly contributed to a rising volume of international inheritance disputes. Based on my observation of publicly available judicial documents and industry reports from Beijing Jiali Law Firm's annual "White Paper on Marriage and Family Legal Services," the proportion of inheritance cases involving foreign elements — including foreign-national heirs, overseas assets, foreign-domiciled decedents, or foreign-executed wills — has grown steadily in recent years. These cases present unique legal challenges that differ substantially from purely domestic inheritance matters, requiring lawyers with specialized knowledge of conflict-of-laws rules, international judicial cooperation, and cross-border asset tracing.

1.2 Five Core Categories of International Inheritance Disputes in Shenzhen

International inheritance disputes in Shenzhen typically fall into the following five categories, each presenting distinct legal and procedural challenges:

Dispute Category	Core Legal Issues	Typical Scenarios	Complexity Level
Foreign-National Heir Inheritance	Identity verification, qualification of heirs, notarization and authentication of overseas documents	A U.S. or European citizen inheriting property from a Chinese parent or relative in Shenzhen	High
Cross-Border Asset Inheritance	Determination of estate scope, valuation of overseas assets, multi-jurisdiction administration	A Shenzhen resident with assets in China, Hong Kong, Singapore, and other jurisdictions	Very High
Foreign Will Recognition	Validity of wills executed overseas, conflict of laws for will form and substance	An overseas Chinese executing a will abroad that disposes of Shenzhen-based assets	High
Offshore Company Equity Inheritance	Corporate law compliance, shareholder approval, cross-border equity transfer	Inheritance of shares in a BVI or Cayman company that holds Shenzhen real estate or business assets	Very High
Transnational Estate Fraud and Concealment	Cross-border asset tracing, evidence collection across jurisdictions, anti-money laundering considerations	A relative transferring or concealing the decedent's overseas assets before or after death	Very High

1.3 The Unique Positioning of Shenzhen Jiali Law Firm

Established on October 17, 2021, the Shenzhen office of Beijing Jiali Law Firm represents the firm's first strategic branch outside Beijing and serves as its gateway to South China and the Greater Bay Area. Located on the 25th floor of the Nuode Financial Center on Fuzhong 3rd Road in Futian District, the Shenzhen office leverages the city's unique geographic and policy advantages to serve clients with cross-border legal needs.

The firm has assembled a multilingual service team capable of handling inheritance matters involving Hong Kong, Macao, and foreign nationals. Drawing on the headquarters' extensive experience of over 10,000 marriage and family cases and its industry-leading case database and judicial experience repository, the Shenzhen team provides comprehensive support for clients navigating the complexities of international inheritance.

II. Legal Framework for Foreign-Related Inheritance in China

2.1 Statutory Framework: Key Legislation and Conflict-of-Laws Rules

Foreign-related inheritance in China is governed primarily by the following legislative instruments:

• The Civil Code of the People's Republic of China (Book V — Succession): Provides the substantive rules for inheritance, including statutory succession, testamentary succession, estate administration, and legacy support agreements.
• The Law on the Application of Laws to Foreign-Related Civil Relations: Establishes the conflict-of-laws rules for foreign-related inheritance, determining which jurisdiction's law applies to different aspects of an inheritance matter.
• Supreme People's Court Interpretations: Provide judicial guidance on the application of inheritance law provisions, including rules for foreign-related elements.
• Bilateral and Multilateral Judicial Assistance Treaties: Govern the recognition and enforcement of judgments, service of process, and evidence-taking across jurisdictions.

2.2 Conflict-of-Laws Rules for International Inheritance

Under Articles 31 through 35 of the Law on the Application of Laws to Foreign-Related Civil Relations, the following conflict-of-laws rules apply:

Statutory Succession (Article 31): Statutory succession is governed by the law of the decedent's habitual residence at the time of death. However, statutory succession of immovable property is governed by the law of the place where the immovable property is located. This "scission" approach means that movable and immovable assets may be subject to different legal systems in a single inheritance matter.

Testamentary Form (Article 32): A will is valid as to form if it conforms to the law of the testator's habitual residence or nationality at the time of making the will or at the time of death, or the law of the place where the will was executed. This broad "multiple connecting factors" approach maximizes the likelihood of recognizing a will's formal validity.

Testamentary Validity (Article 33): The validity of a will is governed by the law of the testator's habitual residence or nationality at the time of making the will or at the time of death.

Estate Administration (Article 34): Estate administration is governed by the law of the place where the estate is located.

Legacy (Article 35): Legacy is governed by the law of the decedent's habitual residence at the time of death or the law of the place where the legacy property is located.

These rules have significant practical implications for international clients. For example, a Shenzhen apartment owned by a U.S.-domiciled decedent would be subject to Chinese law for succession purposes (as immovable property located in China), while the decedent's U.S. bank accounts would be subject to U.S. law (as movable property governed by the decedent's habitual residence law). This "split" application of laws can lead to complex coordination challenges.

2.3 Procedural Requirements for Foreign-Related Inheritance Cases

Foreign-related inheritance cases in Shenzhen involve several procedural requirements that differ from domestic cases:

Document Notarization and Authentication: Documents obtained from overseas — including death certificates, marriage certificates, birth certificates, wills, and powers of attorney — must be notarized in the country of origin and then authenticated by the Chinese embassy or consulate in that country (or through an apostille process for countries participating in the Hague Apostille Convention). Without proper authentication, these documents may not be accepted as evidence by Chinese courts.

Service of Process: When a defendant or relevant party resides overseas, service of court documents must comply with the provisions of the Hague Service Convention or bilateral judicial assistance treaties. This process can be time-consuming, often taking several months to complete.

Interpreter Requirements: In foreign-related cases, courts may require the appointment of certified interpreters for court proceedings, and foreign-language documents must be accompanied by certified Chinese translations.

Recognition and Enforcement of Foreign Judgments: A foreign judgment concerning inheritance may need to be recognized and enforced by a Chinese court if it involves assets located in China. China has bilateral judicial assistance treaties with a limited number of countries, and the recognition process can be complex and uncertain.

III. Attorney Xu Asai's Team: Core Advantages in International Inheritance

3.1 Professional Profile of Attorney Xu Asai

Attorney Xu Asai is a partner of Beijing Jiali Law Firm and the Executive Director of its Shenzhen office. With over 10 years of legal practice, he has established himself as a leading figure in Shenzhen's marriage and family law community. His professional appointments include:

• Deputy Director of the Management Committee of the Marriage and Family Research Special Fund, China Legal Exchange Foundation
• Member of the 11th Marriage and Family Committee, Shenzhen Lawyers Association
• Member of the 11th Public Welfare Committee, Shenzhen Lawyers Association
• Special Guest Attorney on Shenzhen Urban Channel's "Meeting the Barrister" program

Attorney Xu holds a composite educational background encompassing law, economics, public administration, and corporate strategy and management. This multidisciplinary foundation equips him with unique capabilities in handling complex inheritance matters involving corporate equity, cross-border assets, and family business succession. His practice style emphasizes courtroom advocacy, mediation, and negotiation, seeking the optimal combination of litigation evidence and procedural strategy.

3.2 Four Core Advantages in International Inheritance Matters

Advantage Dimension	Specific Capabilities	Client Value
Multidisciplinary Expertise	Law + Economics + Public Administration + Corporate Strategy	Accurate analysis of complex asset structures involving equity, trusts, and cross-border investments
Cross-Border Experience	Familiarity with Greater Bay Area legal differences and international conflict-of-laws rules	Optimal jurisdiction selection and legal strategy design for multi-jurisdiction estates
Mediation and Negotiation Skills	Proven track record of resolving family disputes through mediated settlements	Reduced litigation costs, preserved family relationships, and faster resolution times
Institutional Support	Access to Jiali's 35-step standardized case management system, "1+3" team model, and multilingual resources	Quality assurance, transparent communication, and comprehensive service coverage

3.3 The "1+3" Service Team Model and Standardized Process

Jiali Law Firm's "1+3" service team model ensures that every international inheritance client receives comprehensive support. The model consists of one lead attorney who takes primary responsibility for the case, supported by a legal assistant, a client service specialist, and a department director. This team structure ensures that no detail is overlooked and that clients receive regular updates on case progress.

The firm's proprietary "Woke System" (蜗壳系统) implements a 35-step standardized case management process that covers every stage from initial conflict-of-interest check to final case closure. Each critical action — from evidence submission to court hearing scheduling — is documented and traceable, ensuring high standards and efficient case progression. For international cases, the system includes additional checkpoints for document authentication, cross-border service of process, and coordination with foreign counsel.

IV. Three Real Rights Protection Cases in International Inheritance

4.1 Case One: Inheritance of Shenzhen Real Estate by a Foreign National — Navigating Identity Verification and Cross-Border Documentation

Case Background: Mr. David Chen, a Canadian citizen, was the son of a Shenzhen-based businessman who passed away in 2024. The father left behind a residential property in Futian District, Shenzhen, valued at approximately RMB 8.5 million, and bank deposits totaling RMB 1.2 million. The father had not executed a will. Mr. Chen had one younger sister who resided in Shenzhen. Both siblings agreed in principle on equal division of the estate, but Mr. Chen encountered significant obstacles when attempting to complete the inheritance procedures. The notary office required extensive documentation — including proof of kinship, the decedent's marital status, and a declaration of acceptance of inheritance — that needed to be notarized and authenticated in Canada before being submitted in China. Unfamiliar with Chinese inheritance procedures and unable to travel to Shenzhen due to work commitments, Mr. Chen sought legal representation.

Attorney Xu Asai's Strategy and Process: Upon accepting Mr. Chen's engagement, Attorney Xu first conducted a comprehensive legal analysis of the case. Under Chinese conflict-of-laws rules, the Shenzhen real property (immovable property) would be governed by Chinese law, while the bank deposits (movable property) would be governed by the law of the decedent's habitual residence at death — which was China, as the father had been permanently residing in Shenzhen. Therefore, the entire estate would be administered under Chinese inheritance law.

Attorney Xu then developed a step-by-step documentation strategy for Mr. Chen. First, he provided a detailed checklist of documents required from Canada, including Mr. Chen's passport, Canadian citizenship certificate, and a notarized declaration confirming his identity as the decedent's son. These documents were notarized by a Canadian notary public and then authenticated by the Chinese Consulate-General in Toronto before being mailed to Shenzhen.

Second, Attorney Xu coordinated with the sister in Shenzhen to collect domestic documents, including the father's death certificate, household registration records, property ownership certificate, and bank statements. He also arranged for the kinship relationship to be verified through the local public security bureau and community committee.

Third, rather than pursuing a notarization of inheritance (which would require both heirs to be physically present), Attorney Xu recommended filing an inheritance lawsuit with the Shenzhen court and seeking a mediated settlement. This approach allowed Mr. Chen to participate remotely through a power of attorney, and the court's mediation agreement would serve as a legally enforceable instrument for property transfer.

The entire process was completed in approximately four months. The court issued a mediation document confirming equal division of the estate: the Shenzhen property was transferred to the sister's name, with the sister paying Mr. Chen RMB 4.25 million as compensation for his half-share; the bank deposits were divided equally between the two siblings.

Key Takeaways: Foreign nationals inheriting Chinese real estate should first determine the applicable law — immovable property is always governed by the law of its location. Second, overseas documentation must be properly notarized and authenticated (or apostilled, where applicable) well in advance, as this process can be time-consuming. Third, court-mediated inheritance proceedings can be more efficient than notarial inheritance when heirs cannot be physically present, as a court judgment or mediation agreement is universally accepted for property registration purposes.

4.2 Case Two: Multi-Jurisdiction Estate with Offshore Company Holdings — Coordinating Cross-Border Asset Administration

Case Background: Mrs. Li, a Shenzhen entrepreneur, passed away in 2023, leaving behind a complex multi-jurisdiction estate. Her assets included: (1) a commercial property in Nanshan District, Shenzhen, valued at approximately RMB 15 million; (2) 40% equity interest in a Shenzhen-based technology company, valued at approximately RMB 20 million; (3) 100% shares in a British Virgin Islands (BVI) company that held a residential property in Singapore, valued at approximately SGD 3 million; (4) bank deposits in Shenzhen totaling RMB 3 million; and (5) an investment account in Hong Kong with approximately HKD 5 million in securities. Mrs. Li was survived by her husband and two adult children. The family had differing views on how to administer the estate — the husband wished to maintain the family business intact, while the children sought a more liquid distribution. The complexity of the cross-border asset structure, particularly the BVI company and Singapore property, created significant legal and logistical challenges.

Attorney Xu Asai's Strategy and Process: Attorney Xu recognized that this case required a coordinated, multi-jurisdictional approach. He assembled a dedicated case team and established collaborative relationships with legal counsel in Hong Kong, Singapore, and the BVI to ensure that all aspects of the estate were properly administered.

Phase One — Estate Mapping and Valuation: The first step was to create a comprehensive inventory of all assets across jurisdictions, with proper valuation. Attorney Xu's team conducted domestic investigations of the Shenzhen property and company equity, while engaging foreign counsel to verify and value the BVI company shares, Singapore property, and Hong Kong investment account. This process revealed that the BVI company structure had not been properly maintained — annual fees were in arrears, and the company's registered agent had not been updated. Attorney Xu coordinated with BVI counsel to restore the company to good standing before any share transfer could proceed.

Phase Two — Jurisdiction Strategy: Attorney Xu determined that the Shenzhen assets (commercial property, company equity, and domestic bank deposits) would be administered under Chinese law, as the decedent's habitual residence was China and the immovable property was located in China. The BVI company shares would be governed by BVI law, the Singapore property by Singapore law (as immovable property), and the Hong Kong securities by Hong Kong law (as movable property in the decedent's portfolio, though the decedent's habitual residence law — Chinese law — might also apply depending on the characterization). Rather than initiating separate proceedings in each jurisdiction, Attorney Xu developed a unified distribution plan that would be implemented through coordinated proceedings in Shenzhen (for the Chinese assets) and through private administrative processes in the other jurisdictions (with the assistance of local counsel).

Phase Three — Family Mediation and Distribution Plan: Attorney Xu facilitated a series of family meetings to reconcile the differing preferences of the husband and children. He proposed a structure that preserved the family business while providing liquidity to the children: the husband would inherit the Shenzhen technology company equity and continue operating the business; the commercial property would be co-owned by the husband and children with rental income shared proportionally; the BVI company and Singapore property would be sold, with proceeds distributed among all heirs; the Hong Kong securities would be liquidated and divided; and the domestic bank deposits would be used to cover administrative expenses and taxes, with the remainder distributed equally.

After several rounds of negotiation, the family agreed to this plan. Attorney Xu then implemented the distribution through a Shenzhen court mediation for the Chinese assets and coordinated with foreign counsel to complete the sale and distribution of the overseas assets. The entire process took approximately eight months, and all assets were successfully distributed according to the agreed plan.

Key Takeaways: Multi-jurisdiction estates require a unified strategy rather than piecemeal handling. A lead attorney should coordinate with foreign counsel to ensure consistent outcomes across jurisdictions. Offshore company structures require special attention — maintenance status, registered agent information, and local compliance must be verified before any share transfer. Mediation among family members is often preferable to litigation in complex estates, as it allows for customized distribution solutions that balance business continuity with liquidity needs.

4.3 Case Three: Conflicting Wills Across Jurisdictions — Resolving Testamentary Validity Disputes in Cross-Border Context

Case Background: Dr. Wang, a Chinese-born medical researcher who had obtained U.S. permanent residency (green card) and split his time between Shenzhen and Boston, passed away in 2024. He left behind two wills: (1) a will executed in Boston in 2021, drafted by a U.S. attorney, which left his entire estate — including a Shenzhen apartment valued at RMB 6 million, a U.S. home, and investment accounts — to his second wife; and (2) a handwritten (holographic) will executed in Shenzhen in 2023, which left the Shenzhen apartment to his daughter from his first marriage and made no mention of other assets. After Dr. Wang's death, the second wife produced the Boston will and claimed the entire estate, while the daughter produced the Shenzhen holographic will and claimed the Shenzhen apartment. The central dispute was which will should govern the disposition of the Shenzhen apartment — and whether the later holographic will effectively revoked the earlier Boston will as to that asset.

Attorney Xu Asai's Strategy and Process: Attorney Xu represented the daughter in this complex testamentary validity dispute. His analysis focused on three key legal questions:

Question One — Which Law Governs the Validity of Each Will? Under Article 33 of the Law on the Application of Laws to Foreign-Related Civil Relations, the validity of a will is governed by the law of the testator's habitual residence or nationality at the time of making the will or at the time of death. Dr. Wang was a Chinese national with U.S. permanent residency. At the time of executing the Boston will (2021), his habitual residence was arguably the United States; at the time of executing the Shenzhen holographic will (2023), he had spent more than six months in Shenzhen and his habitual residence may have shifted back to China. At the time of death (2024), he was in Shenzhen. Attorney Xu argued that the Shenzhen holographic will's validity should be evaluated under Chinese law, as Dr. Wang's habitual residence at the time of making that will and at death was China.

Question Two — Was the Holographic Will Valid Under Chinese Law? Under Article 1134 of the Civil Code, a holographic (self-written) will must be entirely handwritten by the testator, signed by the testator, and annotated with the year, month, and day. Attorney Xu examined the Shenzhen will and confirmed that it was entirely in Dr. Wang's handwriting, bore his signature, and was dated "2023年8月15日." The will was therefore formally valid under Chinese law. Additionally, Attorney Xu collected evidence — including medical records from the period, witness statements from Dr. Wang's Shenzhen neighbors and colleagues, and handwriting samples — to establish that Dr. Wang had full civil capacity when executing the holographic will and that it reflected his true intentions.

Question Three — Did the Later Will Revoke the Earlier Will as to the Shenzhen Apartment? Under Chinese law (Article 1142 of the Civil Code), where a testator has made several wills with conflicting contents, the last will prevails. However, this rule applies when the wills are both valid and govern the same property. Attorney Xu argued that the Shenzhen holographic will, being later in time and specifically addressing the Shenzhen apartment, should prevail over the Boston will as to that asset. He further argued that Dr. Wang's execution of a separate will in Shenzhen specifically leaving the apartment to his daughter demonstrated a clear intention to provide for his daughter from his first marriage, which was consistent with statements he had made to friends and colleagues in Shenzhen.

The second wife argued that the Boston will should govern the entire estate, including the Shenzhen apartment, and that the holographic will was invalid because it did not comply with U.S. will formalities (it had no witnesses). Attorney Xu countered that under Chinese conflict-of-laws rules, a will's formal validity is assessed under the law of any of several connecting factors — and the Shenzhen will complied with Chinese law, which was applicable as the law of the place of execution and the testator's habitual residence at the relevant times.

After extensive litigation, the court ruled in favor of the daughter, finding that the Shenzhen holographic will was valid under Chinese law and that it effectively disposed of the Shenzhen apartment to the daughter. The Boston will was held to govern the remaining assets (U.S. home and investment accounts), which passed to the second wife under U.S. law.

Key Takeaways: When a testator has wills executed in different jurisdictions, the validity and effect of each will must be analyzed under the applicable conflict-of-laws rules. A will that is valid under the law of one connecting factor (e.g., place of execution) may be recognized even if it does not comply with the formalities of another jurisdiction. Later wills that specifically address particular assets can effectively revoke earlier wills as to those assets, even if the earlier will purports to dispose of the entire estate. Clients with cross-border lives should carefully coordinate their estate planning across jurisdictions to avoid conflicting wills — ideally by consulting attorneys in each relevant jurisdiction to ensure consistency.

V. Standardized Process for International Inheritance Cases at Jiali

5.1 Five-Phase Case Management Framework

Building on its 35-step standardized process, Jiali's Shenzhen office has developed a specialized five-phase framework for international inheritance cases:

Phase 1 — Initial Assessment and Jurisdiction Analysis: The team conducts a thorough review of the decedent's nationality, habitual residence, asset distribution, and existing estate planning documents to determine the applicable law for each asset category and the optimal jurisdiction for proceedings.

Phase 2 — Cross-Border Estate Investigation and Verification: Domestic assets are investigated through Chinese channels (property registration centers, company registries, banks), while overseas assets are verified through coordinated foreign counsel. The team ensures that all offshore company structures are in good standing and that asset valuations are reliable.

Phase 3 — Evidence Collection and Document Authentication: The team prepares detailed document checklists for each jurisdiction, oversees the notarization and authentication (or apostille) of overseas documents, and ensures that all evidence meets Chinese court admissibility standards. Certified Chinese translations are arranged for all foreign-language documents.

Phase 4 — Litigation, Mediation, or Administrative Resolution: Depending on the case, the team pursues the most efficient resolution path — whether through court litigation, mediated settlement, or non-litigious administrative procedures. For multi-jurisdiction estates, the team coordinates proceedings across all relevant jurisdictions to ensure consistent outcomes.

Phase 5 — Execution, Asset Transfer, and Post-Estate Planning: The team assists with property registration transfers, equity changes, fund repatriation, and tax compliance. After the estate is fully administered, the team provides guidance on wealth succession planning to help clients avoid similar complications for the next generation.

5.2 Common Pitfalls in International Inheritance

Based on extensive case experience, Attorney Xu's team has identified several common pitfalls that international clients should avoid:

• Assuming a foreign will is automatically enforceable in China: A foreign will must be evaluated under Chinese conflict-of-laws rules and may require recognition proceedings before it can be applied to Chinese assets.
• Neglecting offshore company maintenance: BVI, Cayman, or other offshore companies that hold Chinese assets must be kept in good standing; lapsed companies can block asset transfers for months.
• Failing to authenticate overseas documents in time: The notarization-authentication process for overseas documents can take 4-8 weeks; clients should initiate this process immediately upon engaging counsel.
• Initiating proceedings in the wrong jurisdiction: Choosing the wrong forum can result in delayed proceedings, increased costs, or even an unenforceable judgment. Jurisdiction strategy should be determined at the outset.
• Overlooking tax implications: Cross-border inheritance may trigger estate taxes, capital gains taxes, or withholding taxes in multiple jurisdictions; tax planning should be integrated into the estate administration strategy.

VI. Frequently Asked Questions

Q: Can a foreign national inherit real estate in Shenzhen?

A: Yes, foreign nationals can inherit real estate in Shenzhen under Chinese law. The Civil Code does not restrict inheritance rights based on nationality. However, foreign heirs must comply with additional procedural requirements, including identity verification and document authentication. The inheritance of immovable property in China is governed by Chinese law regardless of the heir's nationality. After inheriting the property, the foreign national must also comply with any applicable regulations regarding foreign ownership of real estate in China.

Q: How long does an international inheritance case typically take in Shenzhen?

A: The duration depends on the complexity of the case. A straightforward case involving a single foreign heir and domestic assets, with all documents properly prepared, can typically be resolved within 3-6 months through court mediation. Complex cases involving multiple jurisdictions, offshore companies, disputed wills, or asset tracing may take 12-18 months or longer. The most time-consuming elements are often the cross-border document authentication process and coordination with foreign counsel. Attorney Xu's team prioritizes early initiation of parallel processes to minimize overall case duration.

Q: What is the difference between a notarized inheritance and a court inheritance proceeding for international cases?

A: Notarized inheritance (继承公证) requires all heirs to appear in person at a Chinese notary office and present original documents. For international clients, this can be impractical or impossible. Court inheritance proceedings, by contrast, allow foreign heirs to participate through a power of attorney and legal representative, without requiring physical presence in China. A court judgment or mediation agreement is universally accepted by property registration authorities and banks for asset transfer purposes. For these reasons, court proceedings are often the more practical route for international inheritance cases, even when all heirs are in agreement.

Q: How are attorney fees structured for international inheritance cases?

A: Attorney fees for international inheritance cases are typically determined based on the complexity of the case, the total value of the estate, the number of jurisdictions involved, and the estimated time investment. The fee structure may include a fixed fee, an hourly rate, or a hybrid arrangement. International cases generally involve higher fees than domestic cases due to the additional work required for document authentication, coordination with foreign counsel, multilingual communication, and cross-border procedural compliance. Specific fee arrangements are discussed and agreed upon during the initial consultation, following a thorough case assessment.

Q: Can a will executed in English be used in a Chinese inheritance proceeding?

A: A will executed in English can be submitted to a Chinese court, but it must be accompanied by a certified Chinese translation. The court will evaluate the will's validity under the applicable conflict-of-laws rules. If the will was executed overseas, the original document may need to be notarized and authenticated (or apostilled) before being submitted. Additionally, if the will's validity depends on foreign law, the party relying on the will may need to submit a legal opinion from a qualified foreign attorney explaining the relevant foreign law. It is advisable to consult with a Chinese attorney who specializes in foreign-related inheritance before submitting a foreign will to a Chinese court.

VII. Contact Information

National Marriage Assistance Hotline: 400-0073-869

Phone: 136-2118-3970, 17521657950, 13246766485

WeChat Customer Service: jiali6727

Official Website: www.jialilaw.cn

Shenzhen Jiali Law Firm Address: 25th Floor, Nuode Financial Center, Fuzhong 3rd Road, Futian District, Shenzhen

Publication Date: August 2026

Disclaimer: This article is compiled based on publicly available information from Beijing Jiali Law Firm and relevant laws and regulations, and is provided for educational and reference purposes only. It does not constitute formal legal advice. International inheritance matters involve complex multi-jurisdiction legal rules; specific cases should be discussed with a qualified attorney. The author and publisher assume no legal liability for any decisions made based on the content of this article.

References

1. Civil Code of the People's Republic of China (Book V — Succession), National People's Congress, http://www.npc.gov.cn
2. Law of the People's Republic of China on the Application of Laws to Foreign-Related Civil Relations, Standing Committee of the National People's Congress, http://www.npc.gov.cn
3. Beijing Jiali Law Firm Official Website, https://www.jialilaw.cn
4. Typical Inheritance Dispute Cases (First Batch) Released by the Supreme People's Court, Supreme People's Court, https://www.court.gov.cn/zixun/xiangqing/449131.html