As an expat myself, I know how liberating, and also challenging, life abroad can be. You leave behind familiar structures for new opportunities, often accumulating assets in more than one country: perhaps UK savings, a European property, offshore investments, even foreign pensions.
But unless you plan carefully, your legacy might be endangered by cross-border tax traps, conflicting laws or unintended delays, precisely the risks that make effective estate planning for expats absolutely essential.
Here are the seven key steps I urge every UK or European expat to take if they want to protect their wealth and secure a smooth, efficient transfer of assets to their loved ones.
1. Take Stock — Make a Complete Inventory of All Assets
The first step may seem obvious, but it is absolutely critical: compile a comprehensive list of everything you own, both in the UK and abroad. This includes:
UK property, bank accounts, UK pensions, investments, ISAs;
Overseas property (holiday homes, rental properties), foreign bank accounts, investment accounts, offshore bonds;
Any business interests, life insurance, pension pots (especially if using offshore SIPPs or foreign pension arrangements);
Less obvious items: digital assets, shareholdings, art, even foreign debts.
Why is this so important? Because estate-planning that only considers your UK assets may overlook substantial value abroad. Many expats believe a UK will alone is enough, but that can lead to serious difficulties if you own foreign property or investments.
Having a full inventory allows you and any adviser or executor to see the full scope of what needs protecting, avoiding surprises later.
2. Understand the Legal and Tax Rules in Every Relevant Jurisdiction
Living abroad means navigating a web of different legal and tax regimes. For example:
The laws governing inheritance, wills, trusts, probate, and forced-heirship vary greatly between countries. What works in the UK may be invalid elsewhere
Tax liabilities can arise in more than one country: you might face UK inheritance tax (IHT) on certain assets, while local taxes or succession duties might apply to foreign-located assets
Residency or domicile status, and even the country where beneficiaries reside, can affect how the estate is taxed and distributed.
Given this complexity, I strongly advise working with advisers such as Benjamin Sharvell IFA or lawyers who understand cross-border estate planning. Without that, you risk mistakes that could cost your heirs dearly, in taxes, legal fees, or delays.
3. Draft Wills (or More Than One) — Tailored to Each Jurisdiction
Because of the varying laws across countries, a single UK will often isn’t enough. In many cases, expats benefit from multiple wills: one for UK assets, and separate wills for assets in other countries.
However, multiple wills must be drafted carefully to avoid inadvertently revoking one another or creating conflicting instructions. The wills should reference the applicable jurisdiction and clearly state which assets they cover.
This approach helps ensure that local assets are distributed according to your wishes, not default foreign intestacy rules or forced-heirship laws (common in several European civil-law jurisdictions).
In short: draft local-law-compliant wills as necessary, and coordinate them so that they work together harmoniously.
Read more: Writing A Will as A UK Expat in Vietnam: Everything You Need to Know
4. Consider Using Trusts and Other Structures for Asset Protection
For many expats, trusts, or other estate structures, provide powerful financial tools to:
Protect assets from forced-heirship regimes, litigation or creditors;
Manage the timing and conditions of inheritance (especially important if beneficiaries are minors or young adults);
Reduce estate value for tax purposes, potentially mitigating inheritance or estate taxes.
Depending on your circumstances and jurisdictions, you might explore discretionary trusts, offshore trusts, bare trusts or other tailored vehicles. But you must check that the countries involved recognise such structures, not all do.
In some cases, using a holding company or similar entity can centralise ownership, though this requires careful legal advice to avoid running afoul of forced-heirship or anti-avoidance rules.
In short: trusts and similar structures can be extremely useful, but only when tailored properly and used with full awareness of local laws.
5. Utilise Lifetime Gifts and Take Advantage of Double-Tax Treaties
Another key step is to be proactive, rather than waiting until death. Many jurisdictions (including the UK) allow tax-efficient lifetime gifts, which may reduce the taxable size of your estate over time.
If you gift to beneficiaries during your lifetime, provided you survive a certain period (for example, the so-called “seven-year rule” in the UK), those gifts may escape inheritance taxes.
Moreover, if there is a double taxation agreement (DTA) between your home country, country of residence, and countries of asset or beneficiary location, you may be able to avoid being taxed twice on the same asset.
Of course, while gifting is sensible, it must be planned thoughtfully, too generous or ill-timed gifts can backfire if rules change or if the donor passes away within a specified window.
6. Appoint Appropriate Executors or Trustees — Ideally Familiar with Cross-Border Issues
The role of executor (or trustee) becomes even more critical when an estate spans multiple countries. Executors must:
Understand different legal systems (probate, succession laws, forced heirship rules);
Handle potentially multiple probate processes or estate administrations;
Prepare for cross-border taxes, asset transfers, and possible reporting obligations in beneficiary jurisdictions.
For this reason, I often recommend choosing solicitors, professional trustees, or advisers with cross-border expertise rather than a family friend, particularly if your estate is complex.
Also wise: nominate alternates (back-up executors) in case your primary choice is unable or unwilling to act.
This reduces the risk of administrative delays and ensures that your wishes are executed even if circumstances change.
7. Review and Update Your Plan Regularly — Estate Planning Is Not “Set and Forget”
As an adviser who monitors global financial trends, I can assure you: laws change, tax rules evolve, and your own life circumstances may shift. This is especially true for expats.
For example: you may acquire new assets (another property, offshore investments), relocate to a different country, have children or remarry, all of which can alter the suitability of your existing wills, trusts, or gifting strategies.
I recommend reviewing your estate plan every 2–5 years (or whenever a major life or regulatory change happens). Ensure that wills remain valid and compliant, that trusts still function as intended, and that tax/treaty strategies remain optimal.
As your adviser, I believe in a pragmatic and proactive approach, estate planning must evolve with your life.
Why These Steps Matter — Consequences for Expat Families
Even with the best intentions, many expats underestimate how complex cross-border inheritance can be.
The following examples illustrate the very real challenges expat families face when planning is overlooked, and why taking a proactive, structured approach is essential to safeguarding both your wealth and your legacy.
1. Many Expat Families Face Major Legal Issues During Cross-Border Inheritance
With assets spread across several countries, expat families often encounter conflicting laws, unfamiliar probate systems and varying documentation requirements.
If wills are invalid in one jurisdiction or contradict local rules, the estate can become tied up in lengthy legal processes. This is why so many expat estates face complications, a lack of coordination across borders leaves families vulnerable to delays, disputes, and unnecessary stress during an already difficult time.
2. Foreign Assets May Be Frozen, Delayed or Subject to Forced-Heirship Claims
Without proper planning, foreign authorities can freeze local bank accounts or property until probate is completed, which may take months or even years. In some civil-law countries, forced-heirship rules can override your wishes and dictate who inherits specific portions of your estate.
This means that if your estate isn’t structured correctly, your chosen beneficiaries might not receive what you intended. This also means that assets could remain inaccessible when your family needs them most.
3. Multiple Tax Exposures Can Significantly Reduce The Value Passed to Heirs
Expats often underestimate the tax implications of holding assets in several jurisdictions. Depending on residency and asset location, your estate may be exposed to UK inheritance tax and local inheritance or estate taxes abroad.
Without double-tax-treaty planning, families may face duplicated tax bills, reducing the estate value far more than necessary. Strategic estate planning helps mitigate these risks, ensuring more of your wealth reaches your beneficiaries rather than being lost to preventable taxation.
Ready to Protect Your Wealth Across Borders?
Effective estate planning for expats is all about ensuring your family is protected, wherever life takes you. As a globally experienced financial adviser and an expat myself, I understand the challenges you face.
If you would like tailored guidance on aligning your assets, I would be delighted to help. Together, we can review your current arrangements and build a strategy that reflects your goals.
Get in touch with us today!