📜 Civil Code (general rules) · Awareness case
Cross-Border Inheritance: Dealing with Foreign Assets Inherited in China · Yalla China
🤝 Governing law: القانون المدني / Civil Code (2021) Book 6 + Law on Application of Laws to Foreign-related Civil Relations (2010)
The Law on Application of Laws to Foreign-related Civil Relations (2010) regulates how to determine the applicable law for inheritance that includes assets in China and abroad.
Illustrative, general educational examples — not real specific facts and not legal advice; for awareness only. For an actual situation, consult a licensed lawyer.
Under the Civil Code (2021) and Law on Application of Laws to Foreign-related Civil Relations (2010): Conflict of laws rules in inheritance: (1) Movable assets (stocks, bank accounts, jewelry): law of the deceased's nationality or domicile applies; (2) Chinese real estate: Chinese law always applies; (3) Procedures: notarized will/succession document + apostille + certified translation required. Distribution of Chinese assets to foreign heirs: subject to Chinese inheritance law and foreign exchange restrictions. Tax: no inheritance tax applies in China currently. Statute of limitations: 3 years from the date of knowledge of the right.
🎓 The lesson / takeaway
If you have assets in China and abroad, consult a lawyer specializing in international estate planning to avoid legal conflict and loss of rights.
🕒 Updated: 16 March 2026