Dragon Gate Trust, Shanghai

The Problem#

• Chinese cross-border estates involve at least two legal systems: PRC succession law (Civil Code Book 6, 2021) for mainland assets, and common law for Hong Kong or Singaporean assets
• The PRC requires notarisation of succession — a notarised will or a notarised inheritance document, depending on whether the estate is testate or intestate
• Hukou (household registration) determines which notary office has jurisdiction — and the hukou may be in a different city from the assets
• Hong Kong’s MPF (Mandatory Provident Fund) death benefits follow separate nomination rules under Cap. 485
• Singapore’s CPF has its own nomination system distinct from the will
• Coordinating across three jurisdictions currently requires three separate sets of advisers with no shared data format

How They’d Use INHERIT#

• estate.json as the root, with assets tagged by jurisdiction using common/jurisdiction.json
• The prc-china extension models applicableLaw ("prc_succession_law_1985" vs "prc_civil_code_2021"), forcedHeirship with firstOrderHeirs[] and secondOrderHeirs[], hukouReferences[] with hukouLocation and hukouType, and notarisationRequired with notarisationDetails
• crossBorderHandling coordinates the PRC-Hong Kong asset split
• The hong-kong extension handles local grant types under Cap. 10 and mpfNomination with nominee details
• The singapore-malaysia extension handles CPF nomination with binding flag
• property.json entries for Shanghai real estate carry the PRC jurisdiction reference; Hong Kong properties carry the HK reference
• common/tax-position.json models double taxation treaty positions between all three jurisdictions

The Integration#

• Bidirectional: Dragon Gate creates a single INHERIT document that all three jurisdictions’ advisers contribute to
• The PRC adviser adds notarisation details and hukou references; the Hong Kong adviser adds grant application details; the Singapore adviser adds CPF nomination data
• The consolidated document gives each adviser visibility into the full picture while they work on their portion

The Business Case#

• Cross-border settlement time reduced from 14 months to 6 months by eliminating duplicated data gathering across three jurisdictions
• Legal fees reduced by approximately 30% — each adviser works from a shared data set rather than independently reconstructing the estate picture
• Hukou-notary jurisdiction matching is automated, avoiding the common error of applying to the wrong notary office (which adds 2–3 months)
• Dragon Gate handles 50–60 cross-border PRC estates per year — the structured approach frees approximately 1,200 adviser hours annually

Before / After#

Without INHERIT:

1. A Hong Kong resident dies with property in Shanghai, investments in Singapore, and a hukou registered in Guangzhou
2. Three separate advisory firms are engaged — one in each jurisdiction — each requesting the same family details, asset inventories, and identity documents
3. The PRC notary in Shanghai rejects the inheritance application because the hukou is in Guangzhou; the process restarts at the Guangzhou notary
4. The Hong Kong grant of probate, PRC notarised succession, and Singapore letters of administration each take their own timeline; nothing is coordinated
5. The estate takes 14 months to settle; the family pays advisory fees in three currencies

With INHERIT:

1. Dragon Gate creates a single INHERIT document with all assets, people, and jurisdictional tags
2. The PRC adviser adds hukouReferences and notarisationDetails — the Guangzhou notary is correctly identified from the start
3. The Hong Kong adviser adds grant details; the Singapore adviser adds CPF nomination
4. All three workstreams proceed in parallel from a shared data set; the estate settles in 6 months