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Scottish and Northern Ireland Succession Law: A Cross-Border Practice Guide for Solicitors

· 21 min

Executive Summary

The United Kingdom comprises three distinct succession law jurisdictions, yet cross-border estate work remains routinely underestimated by practitioners operating primarily within a single system. Scotland's forced heirship regime, its heritable and moveable property distinction, and its separate confirmation process create material risks for solicitors in England and Wales advising clients with Scottish domicile or Scottish assets. Northern Ireland's own legislative framework diverges from both English and Scottish law on intestacy thresholds, will execution formalities, and spousal provision. The Finance Act 2025 has introduced a further layer of complexity by replacing the domicile-based IHT regime with a residence-based test, decoupling tax liability from the succession law connecting factor. This article provides a systematic comparative analysis of all three jurisdictions, structured around the specific decision points practitioners encounter in cross-border instructions, alongside the Law Commission's May 2025 Modernising Wills report.

1. The Three-Jurisdiction Framework

Private client practitioners operating within the United Kingdom must navigate three separate succession law regimes: England and Wales, Scotland, and Northern Ireland.1 Each jurisdiction maintains its own primary legislation governing will execution, intestacy distribution, and estate administration. This tripartite structure is not merely academic; it creates material risks wherever a testator holds assets, owns property, or maintains domiciliary connections across jurisdictional boundaries.

Scotland operates a mixed civil and common law system, with succession principles drawing on both traditions.2 The Society of Trust and Estate Practitioners has described Scotland as "that rare beast, a mixed system of both common- and civil law," noting that its forced heirship provisions align more closely with continental European civil law jurisdictions than with its common law neighbours.2 Northern Ireland, while sharing the common law tradition with England and Wales, maintains distinct statutory frameworks enacted through Orders in Council and devolved legislation, with its own thresholds, procedures, and time limits.

The Scission Principle

English private international law applies the scission principle to cross-border successions: succession to immovable property (land and buildings) is governed by the lex situs -- the law of the jurisdiction where the property is situated -- while succession to movable property is governed by the law of the testator's domicile at death.3 This principle applies with equal force to intra-UK successions as it does to international estates. An English-domiciled testator owning heritable property in Scotland will find that Scottish law governs succession to that property, while English law governs succession to movable assets.

The Wills Act 1963, giving effect to the Hague Convention on the Conflicts of Laws Relating to the Form of Testamentary Dispositions, provides a more permissive framework for formal validity. A will is formally valid if it complies with the law of the place of execution, the testator's domicile, habitual residence, or nationality at the time of execution or at death.4 This flexibility mitigates -- but does not eliminate -- the risk of cross-border invalidity.

The IHT Decoupling: Finance Act 2025

The Finance Act 2025 introduced a fundamental change to the relationship between succession law and inheritance tax. From 6 April 2025, the domicile-based IHT regime was replaced by a residence-based "long-term UK resident" test.5 An individual is now a long-term UK resident if they have been UK tax resident in at least 10 of the preceding 20 tax years. Long-term residents are subject to IHT on worldwide assets, with a "tail" of up to 10 years after departure.

Critically, domicile remains the relevant connecting factor for succession law purposes -- determining which jurisdiction's rules govern the distribution of assets. The result is a decoupling that practitioners must navigate with precision: a client may be subject to Scottish succession law (by reason of Scottish domicile) while also qualifying as a long-term UK resident for IHT purposes, or vice versa.6 The two connecting factors -- domicile for succession, residence for tax -- no longer align in all cases, demanding separate analysis at each stage of cross-border estate planning.

2. Will Execution Divergences

Comparative Requirements

The three jurisdictions impose materially different formal requirements for will execution, creating immediate cross-border risks wherever a testator moves between jurisdictions or holds assets in more than one.

Requirement England and Wales Scotland Northern Ireland
Governing legislation Wills Act 1837, s.9 Requirements of Writing (Scotland) Act 1995 Wills and Administration Proceedings (NI) Order 1994, Art.5
Writing Required Required Required
Witnesses Two, present at same time One (for probative will) Two, present at same time
Minimum testamentary age 18 12 18
Marriage revokes will Yes (s.18) No Yes (Art.12)
Beneficiary as witness Gift to witness voided (s.15) Permitted; gift valid Gift to witness voided (Art.8)
Testator signature location Anywhere on document End of last page of main body Anywhere on document

Scotland requires only one witness for a probative (self-proving) will under the Requirements of Writing (Scotland) Act 1995, compared to two witnesses required in both England and Wales and Northern Ireland.7 The minimum testamentary age in Scotland is 12, as provided by section 2(2) of the Age of Legal Capacity (Scotland) Act 1991, compared to 18 in both other jurisdictions.8 Marriage does not revoke a prior will in Scotland, whereas section 18 of the Wills Act 1837 provides for automatic revocation on marriage in England and Wales, and Article 12 of the 1994 Order makes equivalent provision in Northern Ireland.9

The Wills Act 1837 was largely repealed in Northern Ireland on 1 January 1995 by the Wills and Administration Proceedings (Northern Ireland) Order 1994, except for section 11 (soldiers' privileged wills).10 Northern Ireland's will execution requirements are substantively similar to those in England and Wales, but practitioners must cite the correct legislative authority -- the 1994 Order, not the 1837 Act.

The Law Commission and Widening Divergence

The Law Commission's Modernising Wills report, published in May 2025, proposed reforms applicable exclusively to England and Wales.11 Scotland and Northern Ireland fall outside the Law Commission of England and Wales's remit; each has its own law reform body (the Scottish Law Commission and the Northern Ireland Law Commission, respectively). Key proposals include reducing the minimum testamentary age from 18 to 16, abolishing marriage revocation, introducing electronic wills via a "reliable system," and creating a dispensing power for non-compliant wills.

If enacted, these reforms would narrow certain cross-border gaps with Scotland -- the testamentary age would move from 18 to 16, closer to Scotland's 12; marriage revocation would be abolished, already the position in Scotland. However, new divergences would emerge: electronic wills, which Scotland does not currently provide for, would be valid in England and Wales but not north of the border.12 The Government welcomed the Law Commission's recommendations in May 2025 but confirmed no legislative timetable as of January 2026. Practitioners should treat all proposed reforms as contingent and continue to advise on the basis of current law.

The Revocation Clause Trap

A standard revocation clause -- "I hereby revoke all former wills and testamentary dispositions" -- in a will prepared in one UK jurisdiction can inadvertently revoke a valid will in another jurisdiction.13 This is the most common and most easily preventable cross-border drafting error. Where separate wills are required for assets in different jurisdictions, each will should contain a limited revocation clause confined to the assets it governs (for example, "I revoke all previous testamentary dispositions relating to my assets situated in Scotland"). Solicitors in each jurisdiction should review all existing testamentary documents before executing a new will.

3. Scottish Forced Heirship: The Cross-Border Risk

Scotland's legal rights regime constitutes the single highest-risk cross-border issue for practitioners in England and Wales. Legal rights are a form of forced heirship unique within the United Kingdom. They apply automatically where the deceased died domiciled in Scotland, regardless of the provisions of any will, and cannot be defeated by testamentary disposition.14

The entitlements are fixed by statute. A surviving spouse or civil partner is entitled to one-third of the net moveable estate where there are surviving children, or one-half where there are no surviving children. Children are collectively entitled to one-third of the net moveable estate where there is a surviving spouse or civil partner, or one-half where there is no surviving spouse or civil partner. Legal rights prescribe after 20 years. Where a claimant elects to claim legal rights, they forfeit any provision made for them in the will -- they cannot take both.15

The Heritable and Moveable Distinction

Legal rights apply exclusively to moveable property. Heritable property -- land and buildings -- is excluded entirely from the legal rights calculation.16 This distinction has profound practical implications. The family home, as heritable property, can be left to any person in a will without challenge from legal rights claimants. Conversely, shares in a company that owns land are classified as moveable property and are therefore subject to legal rights claims -- a trap for the unwary.

The Scottish Government confirmed in its 2020 response to the Scottish Law Commission's recommendations that it does not intend to abolish the heritable and moveable distinction in succession law.17 The Scottish Parliament's research briefing of February 2025 (SB 25-06) further confirmed that fundamental reform of Scottish succession law remains stalled, with no consensus on key issues including adult children's legal rights and cohabitant rights.18 Practitioners should assume the current framework will remain in place for the foreseeable future.

Contrast with England, Wales, and Northern Ireland

Neither England and Wales nor Northern Ireland operates a forced heirship system. Both jurisdictions adhere to the principle of testamentary freedom, subject to court-based remedies for dependants. In England and Wales, the Inheritance (Provision for Family and Dependants) Act 1975 permits specified classes of dependant to apply for reasonable financial provision from the estate. Northern Ireland provides equivalent protection through the Inheritance (Provision for Family and Dependants) (Northern Ireland) Order 1979, which permits applications from surviving spouses, civil partners, children, persons maintained by the deceased, and -- following the Succession (Northern Ireland) Order 1996 -- cohabitants of two years' standing. Claims must be brought within six months of the grant of probate.19

The fundamental difference is one of mechanism: in Scotland, legal rights operate automatically and can only be surrendered by the claimant's election; in England, Wales, and Northern Ireland, claims must be actively pursued through the court. An English practitioner who assumes testamentary freedom extends to a Scottish-domiciled client's moveable estate risks catastrophic drafting failure.

Practical Illustration

Consider an English-domiciled testator who acquires Scottish domicile by living and settling in Scotland, and who holds a substantial share portfolio (moveable property). A will leaving the entire estate to a charity, drafted by an English solicitor unfamiliar with Scottish law, would be partially overridden by legal rights. The spouse would be entitled to one-third (or one-half) of the net moveable estate, and adult children would collectively be entitled to a further one-third (or one-half). The charitable gift would be reduced to the "dead's part" -- the residue after legal rights are satisfied.

4. Intestacy Divergences

Three Distinct Frameworks

The three jurisdictions operate materially different intestacy regimes, with different thresholds, distribution hierarchies, and spousal entitlements.

Scotland: Prior Rights and Legal Rights

On intestacy in Scotland, the surviving spouse or civil partner has prior rights that rank above all other entitlements. Prior rights comprise: the dwelling house (up to GBP 473,000); furniture and plenishings (up to GBP 29,000); and a cash sum of GBP 50,000 where there are surviving children or GBP 89,000 where there are no surviving children, with interest at 7 per cent per annum from date of death.20 These thresholds have applied since 1 February 2012 and have not been uprated in over fourteen years -- a period during which residential property values have risen substantially. After prior rights are satisfied, legal rights apply to the remaining moveable estate, and the free estate is distributed according to the statutory order of succession.

The Trusts and Succession (Scotland) Act 2024 introduced a significant change to intestate distribution for deaths on or after 1 May 2024. The surviving spouse or civil partner now ranks ahead of all relatives other than children and their issue in the order of intestate succession.21 Previously, the spouse's right to the free estate was postponed behind siblings and parents. The 2024 Act also extended the time limit for cohabitant claims under section 29 of the Family Law (Scotland) Act 2006 from six months to twelve months from the date of death.

Northern Ireland: Statutory Legacy

Northern Ireland intestacy is governed by the Administration of Estates Act (Northern Ireland) 1955, as amended. The surviving spouse or civil partner receives all personal chattels, a statutory legacy of GBP 250,000 where there are surviving children or GBP 450,000 where there are no surviving children but there are parents or siblings, plus interest at 4 per cent per annum from date of death, and a share of the residue.22 These thresholds have applied since 1 January 2008 and have not been uprated -- creating a significant and widening gap with England and Wales, where the statutory legacy stands at GBP 322,000 following the July 2023 increase.

England and Wales: Statutory Legacy

The surviving spouse or civil partner receives all personal chattels and a statutory legacy of GBP 322,000, with the residue shared between the spouse and children (one-half each where there is one child; one-third to the spouse and two-thirds to children where there are two or more children).

Comparative Intestacy Thresholds

Element England and Wales Scotland Northern Ireland
Governing legislation Administration of Estates Act 1925 Succession (Scotland) Act 1964 Administration of Estates Act (NI) 1955
Spousal statutory legacy GBP 322,000 N/A (prior rights system) GBP 250,000 (with issue) / GBP 450,000 (without)
Dwelling house right No separate provision Up to GBP 473,000 No separate provision
Furniture right Included in personal chattels Up to GBP 29,000 Included in personal chattels
Cash sum Included in statutory legacy GBP 50,000 / GBP 89,000 Included in statutory legacy
Interest rate Not specified 7% p.a. from death 4% p.a. from death
Thresholds last uprated July 2023 February 2012 January 2008
Survivorship period None None 28 days

Northern Ireland remains the "forgotten jurisdiction" in cross-border intestacy guidance. The 28-day survivorship rule under the Succession (Northern Ireland) Order 1996 -- requiring the spouse to survive the deceased by 28 days to inherit on intestacy -- has no equivalent in England and Wales or Scotland, and can produce materially different outcomes in common-disaster scenarios.

Divorce and Will Provisions

The Succession (Scotland) Act 2016 introduced automatic revocation of will provisions in favour of a former spouse or civil partner on divorce, effective for deaths on or after 1 November 2016.23 This brought Scottish law closer to the position in England and Wales (where section 18A of the Wills Act 1837 treats a former spouse's appointment as lapsing). The provision applies unless the will expressly provides otherwise, requiring careful attention to drafting where cross-border divorce is involved.

5. Administration: Confirmation, Probate, and Cross-Border Grants

Procedural Divergences

The three jurisdictions operate distinct estate administration procedures, with differences in terminology, disclosure requirements, executor qualification, and the point at which estate property vests in the personal representative.

Element England and Wales Scotland Northern Ireland
Grant type Probate / Letters of administration Confirmation Probate / Letters of administration
Court High Court (Family Division) Sheriff Court High Court (NI)
Minimum executor age 18 16 18
Maximum executors 4 for a grant No maximum 4 for a grant
Asset disclosure Gross and net estate totals only Full inventory with individual valuations (public) Gross and net estate totals only
Property vesting On death On confirmation On death

Confirmation in Scotland differs materially from probate in England and Wales. Executors must submit a full inventory of assets with individual valuations, which becomes a public document.24 There is no separate grant of letters of administration; all executors in Scotland obtain confirmation, whether the deceased died testate or intestate. The minimum executor age is 16 (compared to 18 in England, Wales, and Northern Ireland). Property vests in the executor only on confirmation, not on death -- creating a potential gap in authority that practitioners must manage.

Additional assets discovered after confirmation require an eik (supplementary confirmation). The eik must be reported to HMRC before the sheriff court will accept the application. Practitioners unfamiliar with Scottish administration should note that the eik procedure has no direct equivalent in England and Wales, where a corrective account to HMRC serves a different procedural function.

Cross-Border Grant Recognition

Statutory provisions ensure mutual recognition of grants across UK jurisdictions. A Scottish confirmation can be resealed in England and Wales under the Administration of Estates Act 1971, and an English grant of probate can be resealed in Scotland.25 However, practitioners should not assume that resealing is automatic or that a single grant suffices for a multi-jurisdictional estate. Specialist advice in each jurisdiction is essential, particularly where the IHT position under the Finance Act 2025 residence-based regime introduces additional reporting obligations.

The IHT payment deadline of six months from the end of the month of death applies regardless of jurisdiction. In cross-border estates, the need to obtain grants in multiple jurisdictions can create acute cash flow challenges, as IHT may become due before all grants are in place and assets can be realised. Early engagement with HMRC and coordinated asset identification across jurisdictions are essential components of effective cross-border administration.

Conclusion: Building a Cross-Border Risk Framework

Practitioners undertaking cross-border estate work within the United Kingdom require a systematic methodology for identifying and managing jurisdictional risk. The analysis above reveals five critical decision points at which divergent rules create material exposure.

First, jurisdiction identification: which succession law governs which assets, applying the scission principle to immovable and movable property separately. Second, will audit: whether existing testamentary documents satisfy the execution requirements of each relevant jurisdiction, and whether revocation clauses are appropriately limited. Third, forced heirship analysis: whether any assets fall within the scope of Scottish legal rights, and whether the heritable and moveable distinction has been correctly applied. Fourth, intestacy modelling: if no valid will exists (or a will is partially invalid), which jurisdiction's intestacy rules apply to each category of asset. Fifth, administration planning: which grants are required, in which courts, and how IHT payment obligations interact with the asset realisation timeline under the Finance Act 2025 residence-based regime.26

The Law Commission's Modernising Wills report, if implemented, will widen rather than narrow several of these cross-border divergences -- making systematic comparative analysis more rather than less important in the years ahead. Northern Ireland's stagnant statutory legacy thresholds and Scotland's stalled succession law reform programme both reinforce the need for ongoing jurisdictional monitoring. Cross-jurisdictional collaboration, whether through dual-qualified practitioners or structured cross-referral protocols, is not a matter of professional courtesy but of risk management.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Private Client, Wills and Succession, Cross-Border Estate Planning, Tax

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Distinguish between the succession law regimes of England and Wales, Scotland, and Northern Ireland in respect of will execution formalities, forced heirship, and intestacy distribution
  2. Analyse the cross-border risks created by Scotland's legal rights regime for English-domiciled testators with Scottish moveable assets, applying the heritable and moveable property distinction
  3. Evaluate the practical implications of the Finance Act 2025 IHT decoupling for cross-border estate planning, differentiating between the domicile-based succession connecting factor and the residence-based tax connecting factor
  4. Apply a systematic five-point risk framework to cross-border instructions involving assets or domiciliary connections in two or more UK jurisdictions

SRA Competency Mapping

  • Functioning Legal Knowledge (SRA Competence Statement A2): Knowledge of the law and procedure relating to wills, intestacy, and estate administration across UK jurisdictions
  • Technical Legal Practice (SRA Competence Statement B6): Ability to identify and assess cross-border legal risks in private client matters
  • Working with Other People (SRA Competence Statement C2): Understanding when to refer to or collaborate with practitioners in other UK jurisdictions

Reflective Questions

  1. How would you identify whether a new client instruction involves cross-border succession issues, and what initial steps would you take to assess jurisdictional risk?
  2. What changes to your firm's will-drafting precedents would be necessary to mitigate the revocation clause trap in multi-jurisdictional estates?
  3. How does the Finance Act 2025 IHT decoupling affect the advice you would give to a client who is UK tax resident but domiciled in Scotland?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 28 January 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Requirements of Writing (Scotland) Act 1995. https://www.legislation.gov.uk/ukpga/1995/7/contents; Wills Act 1837. https://www.legislation.gov.uk/ukpga/Will4and1Vict/7/26; Wills and Administration Proceedings (Northern Ireland) Order 1994. https://www.legislation.gov.uk/nisi/1994/1899/contents ↩

  2. STEP Journal, Issue 1, 2025: "United Kingdom, Separate Systems" (Adelle Seaton TEP). https://journal.step.org/step-journal-issue-1-2025/united-kingdom-separate-systems ↩ ↩2

  3. Kingsley Napley, "Wills and Inheritance: 10 Cross-Border Tips." https://www.kingsleynapley.co.uk/insights/blogs/private-client-law-blog/wills-and-inheritance-10-cross-border-tips ↩

  4. Payne Hicks Beach, "Probate Special Part 4: Cross-Border Issues." https://www.phb.co.uk/article/probate-special-part-4-cross-border-issues/ ↩

  5. Gov.uk, "Technical Amendments to the Residence-Based Tax Regime." https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩

  6. HaysMac, "Major Changes to UK Inheritance Tax: The Move to a Residence-Based Regime from April 2025." https://haysmac.com/insights/major-changes-to-uk-inheritance-tax-the-move-to-a-residence-based-regime-from-april-2025/ ↩

  7. Requirements of Writing (Scotland) Act 1995, s.1(2)(c). https://www.legislation.gov.uk/ukpga/1995/7/contents; Cross Channel Lawyers, "Formal Requirements to Set Up a Valid Will in England, Scotland and Germany." https://www.crosschannellawyers.co.uk/formal-requirements-to-set-up-a-valid-will-in-england-scotland-and-germany-what-are-the-differences/ ↩

  8. Age of Legal Capacity (Scotland) Act 1991, s.2(2). https://www.legislation.gov.uk/ukpga/1991/50/section/2 ↩

  9. Wills Act 1837, s.18. https://www.legislation.gov.uk/ukpga/Will4and1Vict/7/26/section/18 ↩

  10. Wills and Administration Proceedings (Northern Ireland) Order 1994. https://www.legislation.gov.uk/nisi/1994/1899/contents ↩

  11. Law Commission, "Modernising the Law of Wills" (May 2025). https://lawcom.gov.uk/project/wills/ ↩

  12. Balfour and Manson, "From Victorian Quills to Digital Wills: How England's Proposed Reforms Compare to Scottish Law" (May 2025). https://www.balfour-manson.co.uk/2025/05/from-victorian-quills-to-digital-wills-how-englands-proposed-reforms-compare-to-scottish-law/ ↩

  13. Law Society of Scotland Journal, "Cross Border Estates: Some Top Tips." https://www.lawscot.org.uk/members/journal/issues/vol-68-issue-07/cross-border-estates-some-top-tips/; Morgan McManus, "The Difficulty with Cross-Border Wills." https://www.morganmcmanus.com/the-difficulty-with-cross-border-wills/ ↩

  14. Succession (Scotland) Act 1964, ss.10-11. https://www.legislation.gov.uk/ukpga/1964/41/contents ↩

  15. Law Society of Scotland Journal, "Wills, Wealth and Who Gets What: A Fight to Modernise Scotland's Succession Law." https://www.lawscot.org.uk/members/journal-hub/articles/wills-wealth-and-who-gets-what-a-fight-to-modernise-scotlands-succession-law/ ↩

  16. STEP, "Scotland's Heritable/Moveable Property Distinction to Survive Succession Law Reform." https://www.step.org/industry-news/scotlands-heritablemoveable-property-distinction-survive-succession-law-reform ↩

  17. University of Aberdeen School of Law Blog, "Landlocked: The Continuing Separate Treatment of Moveable and Immoveable Property by the Law of Succession in Scotland." https://www.abdn.ac.uk/law/blog/landlocked-the-continuing-separate-treatment-of-moveable-and-immoveable-property-by-the-law-of-succession-in-scotland/ ↩

  18. Scottish Parliament Research Briefing SB 25-06, "Inheritance Law in Scotland" (18 February 2025). https://digitalpublications.parliament.scot/ResearchBriefings/Report/2025/2/18/43c63885-3956-494f-b541-3f83954cc07c ↩

  19. Inheritance (Provision for Family and Dependants) (Northern Ireland) Order 1979. https://www.legislation.gov.uk/nisi/1979/924; Succession (Northern Ireland) Order 1996. https://www.legislation.gov.uk/nisi/1996/3163 ↩

  20. Succession (Scotland) Act 1964, ss.8-9. https://www.legislation.gov.uk/ukpga/1964/41/contents; HMRC Inheritance Tax Manual, IHTM12211. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm12211 ↩

  21. Trusts and Succession (Scotland) Act 2024. https://www.legislation.gov.uk/asp/2024/2; The Gazette, "Changes to Intestate Succession in Scotland" (2024). https://www.thegazette.co.uk/all-notices/content/104227 ↩

  22. Administration of Estates Act (Northern Ireland) 1955, Part II. https://www.legislation.gov.uk/apni/1955/24/part/II; NI Direct, "What to Do If There Is No Will." https://www.nidirect.gov.uk/articles/what-do-if-there-no-will ↩

  23. Succession (Scotland) Act 2016. https://www.legislation.gov.uk/asp/2016/7/notes; Burness Paull, "What the Succession (Scotland) Act 2016 May Mean for You." https://www.burnesspaull.com/legal-insights-news-events/insights/what-the-succession-scotland-act-2016-may-mean-for-you/ ↩

  24. The Gazette, "Confirmation vs Probate: Key Differences." https://www.thegazette.co.uk/wills-and-probate/content/100729; WJM Solicitors, "Probate v Confirmation: A Comparison of the English and Scottish Procedures for Executors." https://www.wjm.co.uk/news/probate-v-confirmation--a-comparison-of-the-english-and-scottish-procedures-for-executors/ ↩

  25. Law Society of Scotland Journal, "Cross Border Estates: Some Top Tips." https://www.lawscot.org.uk/members/journal/issues/vol-68-issue-07/cross-border-estates-some-top-tips/ ↩

  26. Gov.uk, "Technical Amendments to the Residence-Based Tax Regime." https://www.gov.uk/government/publications/residence-based-tax-regime-technical-amendments/technical-amendments-to-the-residence-based-tax-regime ↩