Cross-border legal FAQs by country (click to expand)
Limitation periods vary by state, commonly 2-6 years; confirm early and preserve evidence.
Limitation periods vary by province, commonly 2-6 years.
Limitation for commercial debts is typically 6 years; start early.
Limitation for debts is typically 6 years.
Limitation for commercial debts is typically 6 years.
Under the Limitation Ordinance, the limitation period for debts is generally 6 years; start early and preserve evidence.
General claims lapse after 3 years, running from year-end after maturity; acting late can bar the claim.
General claims lapse after 5 years following the 2020 Civil Code reform.
Dubai's legal environment is creditor-friendly, but bank and fund-flow tracing needs court processes — preserve evidence early and evaluate the DIFC route.
The limitation period for debts is generally 6 years.
The limitation period for debts is generally 6 years.
General claims lapse after 5 years.
General claims lapse after 10 years (Art. 127 Code of Obligations).
Commercial claims generally lapse after 5 years and general claims after 10; confirm by claim type.
General contractual claims lapse after 10 years.
Under the 2015 Civil Code, contract claims lapse after 3 years — start early.
General contractual claims lapse after 5 years.
General claims lapse after 10 years.
General claims lapse after 5 years.
General contractual claims lapse after 10 years.
Contract debts generally lapse after 3 years.
Contract debts generally lapse after 6 years.
Probate is usually required; Chinese notarised documents do not replace local procedure, and local counsel is needed.
Foreigners generally cannot directly own Thai land; special rules apply to inherited property — handle case-by-case with local counsel.
Most states recognise foreign money judgments without requiring reciprocity, but rules differ by state; apply for recognition in the local court and assess early.
Common-law provinces have settled foreign-judgment rules, mostly without reciprocity; apply for recognition under provincial procedure.
No estate tax, but deemed disposition at death can trigger capital gains tax — plan ahead.
Enforcement follows state Foreign Judgments Acts and common law — a settled path; apply for recognition in the local court.
No inheritance tax, but selling inherited property may trigger capital gains tax.
Singapore is a common-law system with a mature foreign-judgment enforcement path; apply for recognition in the local court.
Awards enforce under the New York Convention — fast and predictable, a common route for cross-border disputes.
Enforcement follows the Foreign Judgments Act and common law; apply for recognition in the local court.
Inheritance tax reaches 40% — planning windows matter.
Since 29 January 2024, the Mainland–Hong Kong Arrangement on Recognition and Enforcement of Civil and Commercial Judgments allows most mainland judgments to be recognised and enforced in Hong Kong courts, no longer limited to jurisdiction-agreement cases.
No estate, gift or capital gains tax applies in Hong Kong; cross-border inheritance mainly concerns probate and the linkage of mainland notarised documents.
There is no bilateral treaty; German courts review foreign judgments case-by-case under §328 ZPO (including reciprocity), so outcomes vary and re-litigation is common — assess first.
German inheritance tax is progressive by kinship and amount, up to about 50%; spouses enjoy a high allowance, so early planning matters.
Japanese courts review foreign judgments under Art. 118 CCP, requiring reciprocity among other conditions; China–Japan recognition practice faces hurdles, so re-litigation is common.
Japanese inheritance tax can reach about 55%; spouses enjoy a basic allowance of JPY 160 million, making early planning essential.
The 2004 China–UAE judicial assistance treaty covers judgment recognition and enforcement; applications go to UAE courts, with the federal and DIFC routes differing in efficiency — assess first.
No estate tax applies; since 2020 non-Muslims inherit under codified rules and may inherit by will, while Muslims follow Islamic inheritance rules.
The Reciprocal Enforcement of Judgments Act covers designated countries only; China is not on the list, so re-litigation at common law is usual.
No estate, gift or capital gains tax applies; cross-border inheritance mainly concerns probate and document legalisation.
The Reciprocal Enforcement of Judgments Act 1958 covers Commonwealth and designated countries only; China is not on the list, so re-litigation at common law is usual.
Estate duty has been abolished; note the dual Muslim / non-Muslim succession systems.
No bilateral treaty exists; French courts review foreign judgments case-by-case under private-international-law rules — a settled regime, but assess each case.
French inheritance tax reaches about 45% for direct descendants; spouses are exempt, and property succession involves notarial procedures — plan early.
The 1988 China–Switzerland judicial assistance treaty covers recognition and enforcement of civil and commercial judgments; apply under Art. 25–32 PILA.
No federal estate tax; cantonal estate taxes vary widely, so plan according to the canton of residence.
Korean courts review foreign judgments under Art. 217 CCP with strict reciprocity; China–Korea recognition practice faces hurdles, so re-litigation is common.
Korean inheritance tax is high, top bracket around 40-50%; spouses have an allowance, and planning under current law matters.
Thailand does not recognise foreign judgments; re-litigation in Thai courts is required, with the Chinese judgment usable as reference evidence.
Under the 1998 China–Vietnam judicial assistance treaty, civil and commercial judgments may be recognised and enforced, with the application reviewed by the Supreme People's Procuracy and assigned to a court.
No inheritance tax is levied in Vietnam.
Under Art. 431 of the Dutch Code of Civil Procedure, foreign judgments are not directly enforceable absent a treaty — re-litigation is usually required.
Dutch inheritance tax reaches about 40%, with different rates for spouses and children — plan early.
No bilateral treaty exists; foreign judgments are reviewed for recognition case-by-case under Law 218/1995.
Italian inheritance tax is low: about 4% for spouses and direct descendants, 6-8% for other relatives.
The 1992 China–Spain judicial assistance treaty covers recognition and enforcement of civil and commercial judgments; apply under the treaty.
Spanish inheritance tax varies widely by autonomous community; the state rate reaches about 34%, with significant reliefs in some regions — assess by property location.
Foreign judgments must first be homologated by the Superior Court of Justice (STJ); no dedicated China–Brazil civil judgment treaty exists and the procedure takes time.
Brazilian inheritance tax (ITCMD) is state-level at about 4-8%, varying by state.
Without reciprocity arrangements, re-litigation in India is usual, with the foreign judgment reviewed under s.13 CPC and usable as evidence.
India abolished inheritance tax in 1985.
No bilateral treaty exists; non-EU foreign judgments are usually re-litigated at common law in Ireland.
Irish Capital Acquisitions Tax (CAT) reaches 33%, with a high spouse allowance.