Singapore VCC insights

Singapore Will for Foreigners: Making Two Wills Work Without Revoking Each Other

By VCC Editorial Team · Published 5 November 2026

Short answer: Yes, a foreigner can hold a Singapore will alongside home-country wills, and for Singapore assets it can simplify the grant application. The Singapore will must meet the Wills Act 1838, be limited in scope to defined assets, and use a revocation clause that preserves the other wills, because a later will otherwise revokes earlier ones.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

A Singapore will for foreigners is rarely a stand-alone document. For an international family it is one of two or three wills, each meant to deal with assets in its own country, and each capable of destroying the others through a single careless sentence. This article covers how those wills fit together: formal validity, revocation clauses, which law governs which asset, executors, and when a fresh Singapore grant beats resealing. All statutory references and court guidance were checked against primary sources on 28 October 2026.

Why would a foreign family make a separate Singapore will?

Mainly speed and evidence. A Singapore will in English, naming an executor willing to act here, avoids the foreign-law affidavit that otherwise accompanies most Singapore grant applications for someone who died domiciled abroad.

Paragraph 211(2) of the Family Justice Courts Practice Directions 2024 requires an affidavit of foreign law, or a certificate from a notary practising in the relevant country, on any application for a grant where the deceased died domiciled outside Singapore. There are two exceptions: the executor named in the will applies for probate of a will in the English language, or the whole Singapore estate is immovable property and the grant is limited to it. The expert must then address, among other things, whether the will was properly executed under section 5 of the Wills Act 1838 (para 211(3)).

A home-country will in Mandarin or Bahasa Indonesia does not meet the first exception. A dedicated Singapore will removes that step for the Singapore assets, at the price of coordinating two wills. For the wider choice between a will and a funded structure, see our comparison of a living trust and a will in Singapore.

What makes a will formally valid in Singapore?

A will executed in Singapore must satisfy section 6 of the Wills Act 1838. A will executed elsewhere can also be valid if it satisfies any one of the alternative laws listed in section 5.

Under section 6(2), the testator signs at the foot or end, and the signature is made or acknowledged before 2 or more witnesses present at the same time, who subscribe in the testator’s presence. No form of attestation is required, but paragraph 210(1) of the Practice Directions requires an affidavit of due execution where a will has no attestation clause or an insufficient one, which is slow to obtain from witnesses abroad.

Section 5(2) treats a will as properly executed if its execution conformed to the internal law of the territory where it was executed, of the territory where the testator was domiciled or habitually resided, or of the state of which the testator was a national, in each case either when the will was made or at death. Section 5(3)(b) adds that, so far as a will disposes of immovable property, compliance with the law of the place where the property is located is sufficient.

Two Singapore rules catch foreign families: the minimum age is 21 (s 4), and a gift to an attesting witness or the witness’s spouse is void, although the will stands (s 10).

How do you stop a Singapore will revoking a home-country will?

By limiting both the revocation clause and the dispositive scope of each will to its own assets. Under section 15(b) of the Wills Act 1838, a will or any part of it can be revoked by another will or codicil executed in the manner the Act requires.

Standard precedents open with “I revoke all former wills”. In a multi-will plan, the last will signed then wipes out the others. Section 5(3)(c) reinforces the risk: a later will is treated as properly executed for revoking an earlier will if it conformed to any law under which the earlier will would have been valid. A home-country will signed later, with a general revocation clause, can therefore revoke the Singapore will.

Three further rules matter:

• Marriage. Every will is revoked by the testator’s marriage (s 13(1)), unless it is expressed to be made in contemplation of a particular marriage (s 13(2)). Whether the same marriage also affects a home-country will depends on that country’s law, so the two wills can fall out of step after a wedding.
• Revival. A revoked will is revived only by re-execution or a codicil showing that intention (s 17).
• Speaking from death. A will takes effect as if executed immediately before death (s 19), so “my Singapore assets” captures assets acquired after signing.

Clause	Common error	Safer approach
Revocation	“I revoke all former wills”	Revoke only earlier wills dealing with the same defined assets, and state expressly that the named home-country will (with its date) is not revoked
Scope	No definition of which assets the will covers	Define the assets by location (for example, all property situated in Singapore at death) and exclude assets covered by the other will
Residue	Residue clause in both wills claiming “the rest of my estate”	Each residue clause confined to that will’s defined assets, so no asset is claimed twice or missed
Executors	Same executors appointed in both wills without regard to location	Appoint executors who can act in each country, with a substitute in case one renounces
Marriage	Will signed shortly before a planned wedding	Express the will to be made in contemplation of that marriage (s 13(2)) or re-sign after it

The home-country will needs mirror-image clauses, and local counsel should confirm that its law accepts a will limited to part of an estate.

Which law governs which asset: situs, movables and immovables?

Singapore law distinguishes immovable property, mainly land, from movables such as bank deposits and shares. On intestacy, Singapore land follows Singapore law whatever the owner’s domicile, while movables follow the law of the domicile at death.

The clearest statutory statement is in section 4 of the Intestate Succession Act 1967: the distribution of movable property is regulated by the law of the country in which the deceased was domiciled at death, while immovable property is regulated by the Act wherever the deceased was domiciled. The split matters whenever a will fails, misses an asset or is revoked by accident: a family domiciled in Indonesia could see its Singapore condominium pass under Singapore’s intestacy rules while its Singapore bank account follows Indonesian law.

Section 5(7) of the Wills Act 1838 provides that a will’s construction is not altered by a later change of domicile, but a move can still change which rules apply on death. Asset type also decides whether a Singapore grant is needed at all.

Asset in Singapore	Passes under the will?	Points to note
Condominium or landed property in sole name	Yes; Singapore grant needed	A foreign beneficiary’s interest must be disposed of within 5 years of death unless extended or approved (Residential Property Act 1976)
Property held as joint tenants, no mortgage	No; passes to the survivor	Listed by the Family Justice Courts as an asset that may not need a grant
Bank account in sole name	Yes; grant usually needed	Some may be released under the bank’s own guidelines
Joint bank account with survivorship mandate	Usually no	Depends on the bank documents the account holders signed
Shares in a Singapore private company	Yes; Singapore grant needed	Valued under accepted accounting practices in the Schedule of Assets (PD para 212(4)(c))
Insurance policy with nomination	Certain policies, no	Pays out under the nomination
CPF savings	No	Excluded from the estate; distributed by CPF nomination
Assets held by trustees of a lifetime trust	No	Trustee continues under the trust deed

For US-listed shares, a third country’s situs rules apply; see US estate tax for Singapore residents holding US shares.

Who should be executor in each country?

Someone who can act promptly in that country, whatever their seniority in the family.

The Family Justice Courts’ guidance on filing for a grant of probate asks for the application within 6 months of death, with reasons if later, and indicates about 2 to 3 months to process it. Estates worth up to S$5 million are heard by the Family Courts and larger estates by the Family Division of the High Court. The filing fee for the originating application through the Service Bureau is S$210 to S$240, depending on whether a printed grant is required. A supporting affidavit must follow within 14 days.

An executor named only in the home-country will has no standing under the Singapore will. The Probate and Administration Act 1934 allows letters of administration with the will annexed to be granted to the attorney of an executor who is absent from Singapore (s 14). Naming a Singapore-based co-executor or substitute is usually simpler.

Grant of probate or resealing: which is faster for Singapore assets?

With a Singapore will, a fresh Singapore grant is usually the direct route. Resealing helps where the only will was proved by a Commonwealth or declared court.

Under section 47(1) of the Probate and Administration Act 1934, a grant made by a court of probate in any part of the Commonwealth, or in a territory the Minister has declared under section 47(5), may be sealed by the Family Justice Courts and then has the same force in Singapore as a local grant (s 47(2)). Hong Kong is a declared territory, with a relevant date of 1 July 1997. Grants from non-Commonwealth countries that have not been declared, such as China, Indonesia, the United States and Switzerland, cannot be resealed.

Resealing also waits for the foreign grant; a separate Singapore will lets the Singapore executor proceed in parallel. Our guide to resealing a grant of probate in Singapore covers the procedure, documents and bond requirements.

Applications to rectify a will for clerical error must be made within 6 months of the first grant unless the court permits otherwise (Wills Act 1838, s 28(2)); a resealed grant counts from the date of sealing (s 28(5)).

What sits outside every will?

Anything the deceased did not own alone at death, and anything a statute or contract sends elsewhere.

The Central Provident Fund Board states that CPF savings “are excluded from your estate and therefore cannot be covered by a will”, so family members with CPF savings need a CPF nomination. Joint-tenancy property, survivorship accounts, nominated policies and assets already held by trustees also pass outside the will.

Religion can also displace the general rules. Section 2 of the Intestate Succession Act 1967 states that nothing in the Act applies to the estate of any Muslim or affects the rules of Muslim law on distribution, and the Family Justice Courts ask for an Inheritance Certificate from the Syariah Court in Muslim estates. Muslim families should draft with the Administration of Muslim Law Act 1966 in mind.

See our checklist for assembling a family succession data room.

Singapore will for foreigners: a drafting checklist

1. Map every asset by country and by mode of holding (sole name, joint tenancy, nominee, trust, company), and mark those that pass outside any will.
2. Record domicile, habitual residence and nationality, which drive section 5 and the intestacy fallback.
3. Instruct counsel in each country at the same time, and agree in writing which assets each will covers.
4. Draft a scope clause in each will that defines its assets by location and excludes the other will’s assets.
5. Replace the general revocation clause with a limited one that names and preserves the other will by date.
6. Confine each residue clause to that will’s assets and allocate debts and costs between the estates.
7. Appoint executors who can act in each country, with substitutes, and confirm they are willing to act.
8. Write the Singapore will in English and include a full attestation clause to avoid an affidavit of due execution.
9. Use 2 independent adult witnesses present together; exclude beneficiaries and their spouses.
10. Make or update CPF nominations, insurance nominations and bank survivorship mandates so they match the wills.
11. Review all wills together after any marriage, relocation or major acquisition.

Where Singapore assets sit in a holding company, current registers help the executor; Singapore Secretary Services provides company secretarial support for such entities.

Frequently asked questions

Can a foreigner who does not live in Singapore make a Singapore will?

Yes. The Wills Act 1838 does not restrict wills by nationality or residence. The testator must be at least 21 and the will must meet the signing and witnessing rules in section 6.

Will my home-country will be accepted in Singapore if I do not make a Singapore will?

Often yes as to form (Wills Act 1838, s 5), but a non-English will of someone domiciled abroad needs foreign-law evidence or a resealable foreign grant.

Does getting married revoke my Singapore will?

Yes, unless the will is expressed to be made in contemplation of that marriage (Wills Act 1838, s 13). The effect on a home-country will depends on that country’s law.

Is there estate duty on a foreigner’s Singapore assets?

No. Singapore removed estate duty for deaths on or after 15 February 2008. Home-country inheritance taxes may still apply; see our note on whether Singapore has estate tax.

Sources

• Wills Act 1838 (Singapore Statutes Online)
• Intestate Succession Act 1967 (Singapore Statutes Online)
• Family Justice Courts: How to file for a Grant of Probate
• Family Justice Courts Practice Directions 2024, Part 24
• CPF Board: Do I still need a CPF nomination if I have made a will?

Raffles Corporate Services helps international families and fund managers coordinate Singapore holding structures with their succession plans, alongside VCC incorporation, family office set-up and ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 5 November 2026. The Editorial Team, Variable Capital Companies Act.