Wills Act 2008

If the internal law in force in a place is to be applied to a will, but there is more than one system of internal law in force in the place that relates to the formal validity of wills, the system to be applied is determined as follows:

if there is a rule in force throughout the place that indicates which system of internal law applies to the will, that rule must be followed;

if there is no rule, the system of internal law is that with which the testator was most closely connected either – at the time of his or her death, if the matter is to be determined by reference to circumstances prevailing at his or her death; or in any other case, at the time of execution of the will.