Two wills, two countries, one estate plan.
If you have assets in New Zealand and another country — an Australian holiday home, Pacific Island family land, a business across the Tasman — one will is rarely the right answer. Here’s why, and how DYOdocs handles it.
The problem
Why one will isn’t enough
Probate is granted by the courts of one country at a time. A New Zealand grant deals with New Zealand assets. An Australian grant deals with Australian assets. They don’t automatically reach across borders.
If a New Zealander dies owning a Bay of Plenty home and a Gold Coast apartment, leaving one will, the executors face a choice. They either apply for probate in one country and then reseal that grant in the other, or they apply separately for probate in both. Either way, the family carries the cost.
And resealing has limits. Under section 71 of the Administration Act 1969 (New Zealand), resealing applies only to grants from Commonwealth countries (and Hong Kong by Order in Council). Commonwealth contries includes Fiji, Kiribati, Nauru, Papua New Guinea, Samoa, Solomon Islands, Tonga, Tuvalu, Vanuatu, and the Cook Islands and Niue as part of the Realm of New Zealand. For grants from Tahiti, New Caledonia, American Samoa, French Polynesia, or any other non-Commonwealth Pacific territory, resealing isn’t available at all. The only option is to apply for a fresh New Zealand grant of probate — months of court time and more legal fees.
The DYOdocs solution
Two coordinated wills, drafted in one questionnaire
Two wills, drafted carefully so they don’t overlap or revoke each other, give the family two parallel grants of probate in two countries.
One questionnaire
Answer the questions once
The DYOdocs multi-jurisdictional questionnaire walks you through your assets in both countries in one sitting. Plain English. Save and return any time.
Two coordinated wills
Drafted not to overlap or revoke
Each will is expressly limited to assets situated in its own country. The revocation clauses are limited so neither will accidentally cancels the other.
Two parallel grants
Each country grants probate independently
No resealing required. Family in each country can deal with the assets in their country in parallel. Faster, cheaper, cleaner.
Sign & witness
Country-specific signing instructions
Both wills come with the correct signing and witnessing instructions for their jurisdiction — including the s 6 attesting-witness rule for Sāmoa and the customary land notice for Cook Islands and Niue.
Common scenarios
Five jurisdiction pairs we cover
Each pair gives you two coordinated wills — one for New Zealand, one for the foreign jurisdiction — drafted in a single questionnaire flow.
NZ + Australia
For NZ residents with an Australian holiday house, an investment property across the Tasman, or trans-Tasman business interests.
NZ + Cook Islands
For NZ residents with assets back home in the Cook Islands — family land interests, leases, bank accounts, or business interests.
NZ + Niue
For NZ residents with assets back home in Niue, including customary land interests dealt with separately under Niue law.
NZ + Sāmoa
For NZ residents with assets in Sāmoa. The Sāmoa will is prepared under the Wills Act 1975 with the s 6 attesting-witness rule built in.
NZ + Fiji
For NZ residents with assets in Fiji. The Fiji will is prepared under the Wills Act [Cap 59] (Fiji), entirely separate from the NZ-style framework.
Not based in New Zealand? Each of our country pages also offers a main will for that country paired with wills for any of the other jurisdictions we cover. Visit your country page to see the available pairings.
Questions people ask
Multi-jurisdictional wills — FAQ
The questions that come up before customers commit.
How do I know if I need two wills?
If you own assets only in New Zealand — one will is right. Don’t over-complicate.
If you own assets in two countries — even just a holiday home, a small lease, or a bank account in your country of birth — the question worth asking is: "if I died next month, would my family want to deal with one country’s probate process, or two?" The answer, almost always, is two.
Won’t the second will revoke the first?
Not when it’s drafted properly. A standard "I revoke all former wills" clause would wipe out the first will. That’s why DYOdocs multi-jurisdictional wills include limited revocation clauses — each will only revokes prior wills dealing with assets in that same jurisdiction. The two wills coexist by design.
Why not just have one will and rely on resealing?
Resealing means one country’s grant of probate is recognised in the other country. It works, but it adds 2× the legal fees, several months of delay, and (since NSW moved to electronic probate) further friction with NZ courts that still require physical sealed copies. Two wills, granted independently in their own countries, avoids all of that.
What if the foreign country isn’t in the Commonwealth?
Then resealing isn’t available at all. Under section 71 of the Administration Act 1969 (NZ), resealing applies only to grants from Commonwealth countries (and Hong Kong). For grants from non-Commonwealth Pacific territories — Tahiti, New Caledonia, American Samoa, French Polynesia — the only option is a fresh New Zealand grant, which is months of delay and several thousand dollars in legal fees. The two-wills strategy is the practical fix.
What does it cost?
Each will is at the standard DYOdocs price for that jurisdiction. From $180 per person for two coordinated Family Wills ($90 NZ + $90 foreign jurisdiction). No bundle discount — the value is the coordination, not a price cut.
What if my situation is complex?
Cross-border trusts, business succession, asset protection structures, or anything involving customary land — these are matters where you should consider a Bespoke service from Ross Holmes Virtual Lawyers Limited rather than the DYOdocs self-service questionnaire. The DYOdocs multi-jurisdictional product is for individuals and couples with assets in two countries; complex structures are RHL territory.
Can I read more about the legal background?
Yes. Ross Holmes has written a full article explaining why one will is rarely enough when assets cross borders. Read the two-wills strategy article →
Two countries. Two wills. One questionnaire.
The only platform offering coordinated multi-jurisdictional wills across New Zealand, Australia, and the Pacific. Templates by Ross Holmes Virtual Lawyers Limited.
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