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A typical situation assembled from practice; details are changed.
The request
A British client spends half the year in Phuket, where he owns a condo and a Thai bank account. His house and savings are in the UK. Some years ago his UK solicitor drew up a will: everything he owns, wherever it is, goes to his wife and son, and all earlier wills are revoked. He now wants a Thai will so that his family does not wait longer than necessary for a court, and he worries that the two documents will clash.
What we found
A foreigner may make a Thai will. The usual structure is a Thai will for assets in Thailand and a separate foreign will for the rest (ThaiLawOnline, 1 October 2026). Thailand has no grant of probate: the Probate Court issues an order appointing an administrator, and banks and registrars require that order. A UK grant of probate or US letters testamentary has no force in Thailand. ThaiLawOnline's probate page (3 October 2026) estimates 3 to 6 months to the court order with a Thai will naming an administrator, often 8 to 16 without a will, and 12 to 24 or more with a foreign will. These are market estimates, not statutory deadlines: the 1 October 2026 guide on the same site gives close figures as the total time for the whole case. The rules are stated as of 6 October 2026.
The problem was in the wording. His UK will covered everything, Thai assets included, and revoked all earlier wills. A Thai will with the same clause could be read as revoking the UK will: under Civil and Commercial Code s. 1697 a later will revokes an earlier one only where they conflict, unless the testator declared otherwise. Without the clause, both documents would dispose of the Thai assets, and any difference in wording would leave his family to argue over which prevails. We cannot predict how a Thai court would read a foreign will with no clear boundary: we found no practice on that point.
| What we compared | Thai will | UK will |
|---|---|---|
| Assets | The condo and the Thai account, named in the text | The UK house and savings |
| Form | In writing, dated, signed before two witnesses present together (s. 1656) | Drawn up by his UK solicitor |
| Revocation | Revokes only earlier Thai wills | Does not revoke the Thai will |
| In a Thai court | 3 to 6 months to the court order, estimated | With a foreign will, 12 to 24 months or more, estimated |
Table sources: Civil and Commercial Code ss. 1656 and 1697; ThaiLawOnline (will form, 1 October 2026; court timing, 3 October 2026).
What we did
- We listed his assets by country: the condo and the Thai account, then the UK house and savings.
- His UK solicitor narrowed the UK will to assets outside Thailand and added that it does not revoke the Thai will.
- We drafted the Thai will in Thai and English. It names the condo and the account, the same heirs and an administrator for the court, and says that it revokes only earlier Thai wills and leaves the UK will alone. Choosing an administrator when the heirs are foreigners and the estate includes a condo needs separate attention, so we settled the candidate with the client on its own.
- He signed before two witnesses present together, with the date (s. 1656; ThaiLawOnline).
- We gave his family a checklist: death certificate, both wills, proof of relationship, and the condo and account papers, with foreign documents legalised and translated.
For UK documents the general chain applies: notarisation, authentication by the foreign ministry or its equivalent, legalisation by the Royal Thai Embassy and a Thai translation (Bangkok Translation, 16 August 2026). The Apostille Convention enters into force for Thailand on 28 February 2027, but not for states that object by about 30 December 2026; an apostille is then due to replace the embassy step (HCCH, 6 October 2026). Thai inheritance tax applies only to amounts above THB 100 million from one deceased person (ThaiLawOnline, 1 October 2026). His UK solicitor covers the UK side, including tax.
The result
The Thai will covers only the condo and the Thai account, the UK will covers the rest, and neither revokes the other. If a Thai court is ever needed, ThaiLawOnline (3 October 2026) estimates 3 to 6 months to the order, against 12 to 24 or more with a foreign will; the real time depends on the court. His heirs are foreigners, so each heir's s. 19 status under the Condominium Act should be settled in advance. By the Act's text, an heir with status keeps the condo within the quota, which a juristic-person letter shows, while one without status sells within a year; if he bought the unit with remitted currency (s. 19(5)), the sources disagree about his heirs. A separate case study shows what happens to an heir without status. Other cases may differ with the court and the documents.
The takeaway
Two wills are less likely to conflict when each names its own assets and neither revokes the other.
Our approach to Thai wills is on the page Make a will in Thailand. How to align the two documents: two wills, Thai and home-country. What foreign heirs of a condo face: a foreign heir inherits a condo.
