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Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
Domicile definition

What does Domicile mean? In practice, domicile identifies a person’s permanent home and chief legal connection, used in private international law to decide jurisdiction and the applicable law for matters such as divorce, succession and tax. Across England & Wales, Scotland and Northern Ireland the concept is principally developed in case law (notably Udny v Udny), with statutory adjustments including the Domicile and Matrimonial Proceedings Act 1973 (which ended the dependent domicile of married women and uses domicile in family jurisdiction). In Ireland, the Domicile Act 1991 codifies and reforms the common‑law rules. Key features are broadly consistent across these jurisdictions: - Domicile of...

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Cayman Islands wills for non-Cayman domiciled clients: formal validity (including the 2018 Law), asset situs versus domicile, construction and revocation

Practice notes
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This Practice Note has been prepared in collaboration with Anthony Partridge of Ogier, Cayman Islands, and Wisdom Hon of Ogier, Hong Kong.

Introduction

For individuals who are not Domiciled in the Cayman Islands but personally hold assets located in the Cayman Islands, they may put in place a separate Will governed by Cayman Islands Law to dispose of those assets and ease the subsequent probate process.

Under Cayman Islands law, the governing law for both the formal validity and the essential/material validity of a Will made by a person domiciled abroad depends on the nature of the assets concerned.

For immovable property situated in the Cayman Islands, the applicable law is the lex situs, namely the law of the Cayman Islands.

For movable property, including cash held in bank accounts or shares in Cayman Islands companies (such as Cayman Islands exempted companies), the applicable law is the law of the deceased’s last domicile.

It should be noted that not all shares connected with the Cayman Islands are treated as situated there. Where shares in Cayman Islands companies are listed on a foreign exchange, those shares are taken to be situated in the jurisdiction where that exchange is located...

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Web page updated on 22/05/2026

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