- Lvl 10, 95 North Quay, Brisbane QLD 4000, Australia
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Living between two countries creates unique challenges when planning your estate. You have assets, superannuation, and pension in Australia. Family and property in Sweden. Perhaps you're an Australian living in Sweden, or a Swede who's made Australia home. Either way, standard estate planning doesn't address the complexities you face.
At Forseti Law Australia, we specialise in cross-border estate planning for Swaussie families and international expats. With dual qualifications in both Australian and Swedish law, we understand both legal systems and can create comprehensive plans that protect your assets, minimise tax, and ensure your family in both countries are properly provided for.
Many Swaussies and expats make the mistake of creating a Will in only one country, or worse, creating conflicting Wills that invalidate each other. Without proper coordination between jurisdictions, your estate could face double taxation, extended delays, family disputes, and assets distributed contrary to your wishes. The complexity multiplies when different countries have different succession laws and tax regimes.
Most people don't realise that Swedish and Australian succession laws operate quite differently. Sweden has forced heirship rules protecting children's inheritance rights, whilst Australia allows greater testamentary freedom. Superannuation in Australia isn't automatically part of your estate and requires separate planning. Swedish pension systems, property ownership structures, and inheritance tax considerations add further layers of complexity that standard estate planning doesn't address.
As a qualified Jurist in Sweden and Solicitor in Queensland, Annelie brings unique expertise that's rare in Australia. You're not working with someone who needs to research Swedish law—you're working with a solicitor who understands both systems intimately and can identify conflicts before they become problems.
We create coordinated estate plans that work seamlessly across both countries. You'll understand how your assets will be treated under both legal systems, what tax implications arise, and how to structure your affairs to protect your family efficiently. Our planning considers not just the legal technicalities, but the practical realities of managing estates across continents.
Coordinated Will preparation that addresses assets in both Australia and Sweden whilst respecting the succession laws of each jurisdiction. We ensure your Wills work together rather than conflict, and that executors have proper authority to act internationally.
Strategic planning for Australian superannuation and Swedish pension entitlements including binding death benefit nominations, tax-effective structures, and coordination with your overall estate plan to ensure these significant assets reach your intended beneficiaries.
Guidance on owning and transferring property, bank accounts, investments, and business interests across borders. We advise on tax implications, ownership structures, and succession planning that minimises complications for your executors and beneficiaries.
Specialised advice for blended families with children in both countries, managing cultural differences in inheritance expectations, and ensuring fair treatment of family members regardless of which country they reside in.
Our comprehensive Swaussie and expat planning services cover:
Analysis of how your assets in both countries will be treated under respective succession laws and tax regimes
Creation of complementary Wills for Australia and Sweden that work together without conflicts or unintended consequences
Binding nominations, tax planning, and integration with your estate plan to protect your super for intended beneficiaries
Structures designed to reduce tax obligations in both countries and avoid double taxation where possible
Practical advice for executors on managing estates across borders including currency issues, international probate, and asset transfer
Assistance explaining your plans to family members in both countries to reduce misunderstandings and potential disputes
Our streamlined legal process is designed to ensure client success by providing efficient and effective legal services. We understand that navigating the legal system can be complex and time-consuming
We discuss your connections to both countries, where your assets are located, who your family members are and where they live, and what concerns you have about cross-border planning. This gives us a complete picture of your international situation.
We create a comprehensive inventory of your Australian and Swedish assets including property, bank accounts, superannuation, pension, investments, and business interests. We identify which jurisdiction governs each asset and potential conflict areas requiring careful planning.
We analyse how Swedish and Australian succession laws apply to your specific situation, identify tax implications in both countries, and determine the most effective structures to achieve your goals whilst minimising complexity and cost.
We draft coordinated Wills, Powers of Attorney, and any necessary trust documents. Everything is prepared with both legal systems in mind, ensuring documents are valid and enforceable in the relevant jurisdictions.
Cross-border situations change—you might acquire new assets, family circumstances evolve, or you might relocate. We provide continuing support to update your planning as your international circumstances change over time.
Usually, yes. Whilst it's possible to have one international Will, separate Wills for each country typically work better. This allows each Will to be tailored to the specific legal system and assets in that jurisdiction. The key is ensuring the Wills are coordinated and don't accidentally revoke each other.
Swedish law requires that children receive a certain portion of your estate (their legal portion or "laglott"). However, Australian assets are generally governed by Australian law, which allows greater testamentary freedom. The complexity arises when you have assets in both countries—we help structure your estate to respect Swedish requirements whilst maximising flexibility under Australian law.
Australian superannuation remains subject to Australian law even if you relocate to Sweden. You'll need binding death benefit nominations to control who receives your super, as it doesn't automatically form part of your estate. We coordinate superannuation planning with your Swedish estate planning to ensure everything works together effectively.
Yes, but proper planning is essential. Without coordination, Swedish beneficiaries may face delays obtaining Australian probate, currency conversion issues, tax complications, and difficulty managing Australian property from overseas. We structure estates to minimise these complications and ensure smooth asset transfer across borders.
Australia doesn't have gift tax, but Sweden does have rules around gifts and their impact on inheritance. Large gifts made before death may be brought back into the Swedish estate calculation. We advise on the implications of gifting in both jurisdictions to avoid unintended tax consequences for your beneficiaries.
Annelie Hovler Solicitor of the Supreme Court of Queensland, Australia Jurist, Sverige
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