As a globally experienced financial adviser specialising in wealth management for expat clients, I’ve spent many years helping individuals and families living abroad to structure their finances, not only for growth, but also to ensure their wealth passes to the next generation in the most efficient, secure and tax-effective way.
Succession planning for expats can appear daunting. Yet with careful thought and planning, you can protect your legacy and give your loved ones peace of mind. In this article, I will walk you through a comprehensive guide to succession planning for expats.
What Is Succession Planning?
Before diving deeper, it’s important to be clear on what succession planning actually means, particularly in an expat context.
Succession planning refers to the strategic process of organising how your assets, wealth and personal wishes will be managed, protected and ultimately transferred to your chosen beneficiaries when you pass away. It goes far beyond simply writing a will. Proper succession planning involves:
Understanding the tax implications of your assets in each country
Ensuring your wealth passes smoothly to your loved ones
Protecting your estate from unnecessary taxation or legal delays
Using structures such as trusts, gifts and wills to safeguard assets
Preparing financially for illness, incapacity, or unexpected events
For expats, succession planning becomes even more crucial because your financial life often spans multiple countries. You may have:
Property in one country
Bank accounts and investments in another
Pensions or business interests elsewhere
A spouse or children living in a different jurisdiction
Residency links that create unexpected tax liabilities
Without a good plan, your estate can easily get caught in cross-border complications, unnecessary taxation, or prolonged probate processes, all of which can place financial and emotional strain on your loved ones.
What Has Changed Recently and What It Means for UK Expats
If you are a UK national living abroad, one of the most significant shifts affecting succession planning came into effect on 6 April 2025.
From domicile to residency: the new rules
Historically, the UK’s inheritance tax (IHT) regime relied heavily on the concept of domicile, a legal status loosely based on where you came from, family origin and long-term intention. This meant that even if you had lived abroad for decades, you could remain liable to UK IHT on your worldwide assets.
Under the new regime:
IHT liability now depends on residency history. If you have been UK tax resident for 10 out of the previous 20 tax years, you are regarded as a “long-term UK resident” (LTR).
If you cease UK residency, you may remain liable for IHT on your global assets for a transitional “tail period”, typically 3 to 10 years depending on how long you were resident.
UK “situs” assets (e.g. UK property, UK-registered shares, UK bank accounts) remain liable for IHT, even if you’re long-term non-resident.
What this means: your worldwide estate (not just UK assets) may be at risk, even if you have moved abroad permanently. For many expats, this has re-introduced the need for careful estate planning, not lessened it.
Key Considerations For Expat Succession Planning
Here are the critical issues you need to address, particularly if you hold assets across multiple jurisdictions.
1. Understand Tax and Succession Law in Each Relevant Jurisdiction
Different countries treat foreign nationals and foreign assets in very different ways. Some impose inheritance tax based on where you live, others based on where the asset is held, and others based on your citizenship. Some countries enforce “forced heirship”, which limits who you can leave assets to, while others allow complete freedom.
Expats will often need either:
A single “international will” recognised in multiple jurisdictions; or
Separate wills in each country where they own significant assets (especially real estate).
Why it matters: A will drafted in your home country may not be recognised abroad, or it may conflict with local law. Without understanding these rules, you risk unintended outcomes, such as assets passing to the wrong person or incurring unnecessary tax.
Actionable tips:
Consult a lawyer in each country where you have property or significant investments.
Ask whether your chosen country applies “forced heirship” and how it affects foreign nationals.
Consider whether a single international will or multiple local wills is the best structure.
Example: A British person who buys a home in France may be surprised to learn that French law automatically reserves a portion of the estate for children, regardless of what their UK will states. Understanding this early allows them to explore EU succession regulation elections or alternative ownership structures.
2. Evaluate Your Liability to Inheritance/Estate Tax (and Plan Accordingly)
Tax exposure is often the most complex part of succession planning for expats. You may be liable for inheritance or estate tax not only based on the country where you live, but also where your assets are situated or where you previously resided.
If you are connected to the UK:
Under the new rules, you could be liable to IHT on your worldwide estate if you meet the long-term residency test.
Even after you cease UK residence, the “IHT tail” may continue for up to 10 years.
UK situs assets remain in scope of IHT regardless.
Why it matters: Cross-border estates can sometimes be taxed twice, once in each jurisdiction, unless a tax treaty or careful planning prevents it. Understanding your exposure enables you to implement strategies that preserve more of your wealth for your loved ones.
Actionable tips:
Check whether your home and host countries impose inheritance or estate taxes.
Review your past residency history, many countries have “tail rules” that continue taxing past residents for years after departure.
Consider lifetime gifting or restructuring if you expect a large taxable estate.
Example: A former UK resident living in Singapore may still be liable for UK inheritance tax on worldwide assets if they lived in the UK for a significant portion of the previous two decades. Without planning, this could mean a 40% tax bill for heirs, even on assets in Asia.
3. Consider Tools Beyond A Will: Gifts, Trusts and Lifetime Transfers
A will is an essential foundation, but it is rarely enough for expats with cross-border interests. Additional planning tools can help reduce tax exposure, offer more control, and streamline the transfer of assets such as:
Gifting during your lifetime: assets given well before death may fall outside estate tax, provided local law allows and documentation is correct.
Trusts: using domestic or offshore trusts can sometimes help manage and distribute assets, preserve privacy, and potentially reduce tax exposure.
Charitable legacies: in some regimes, donating a portion of your estate to charity (e.g. 10% or more) can reduce tax liability.
Why it matters: Many estate planning solutions only take effect if arranged while you’re alive. Trusts, gifting strategies, and certain investment structures can significantly reduce tax liability or bypass slow probate systems, but only if implemented early.
Actionable tips:
Use lifetime gifts to gradually reduce the taxable value of your estate.
Consider establishing a trust for long-term control, especially for property or investments in countries with complex probate.
Review whether certain life insurance policies can provide tax-efficient liquidity for heirs.
Example: An expat with children under 18 may place investment assets into a discretionary trust. This allows them to choose trustees they trust, delay access until children reach adulthood, and potentially protect the assets from inheritance tax depending on jurisdictional rules.
Practical Steps: Succession Planning for Expats — A Checklist
Here is a practical roadmap you can follow.
1. List All Your Assets and Liabilities Globally
The first step in succession planning is to document every asset and liability you hold worldwide. This provides clarity and prevents oversight, especially when assets span multiple countries. Your assets could be:
Property (home country, foreign residence, vacation homes)
Bank accounts, investment portfolios, pensions
Business interests
Life insurance, pensions, trusts, offshore holdings
Personal possessions and valuables
To make this easier, you can:
Use a simple spreadsheet to track: asset type, location, value, ownership structure, and associated documents.
Attach digital copies of deeds, policy statements or account details to your record.
Add notes on which assets may require local probate or special treatment.
Example: Someone living in Hong Kong might own a UK pension, an apartment in Portugal, a joint bank account in the UAE and a share portfolio held via an international broker. By listing these clearly, their executors can identify each asset quickly rather than searching across jurisdictions.
2. Record Where Each Asset is Located and How It Is Owned
Once your list is complete, the next step is to specify the physical or legal location of each asset, as this determines which tax, succession or probate rules apply.
Equally important is noting how each asset is owned: individually, jointly, through a company, or in a trust. These details significantly influence how quickly and efficiently assets can be transferred to your beneficiaries.
Key points to include:
Country in which the asset is registered
Whether it is held personally, jointly, or via an entity
Any special ownership structure (e.g., usufruct rights, community property rules)
Value and currency
Example: A couple owning a villa in Italy under joint tenancy may assume the property automatically passes to the surviving spouse. However, under Italian law, forced heirship rules may still apply. Knowing this upfront helps avoid surprises.
3. Check Your Residency History (Especially In The UK), and Understand How That Affects Estate Tax Liability
Residency history is a major factor in determining tax liability, particularly under the UK’s post-2025 reforms.
Understanding your historical residency helps you evaluate whether your worldwide assets may still fall under your home country’s inheritance or estate tax rules, even if you have lived abroad for years.
What to do:
Review your residency status for at least the past 20 years.
Identify whether you fall under long-term residency rules or tail-period taxation.
Consider whether you may owe inheritance or estate tax both in your current country of residence and in your previous one.
Example: A professional who lived in the UK for 12 of the past 20 years and then moved to Switzerland may still be considered within the UK IHT “tail” for several years. This means their global estate could remain exposed to UK inheritance tax even after relocation. Planning early helps manage this risk.
4. Engage Legal/Tax Professionals in Each Relevant Jurisdiction
Because each country has its own legal and tax system, working with international specialists ensures that your estate plan is both valid and efficient across borders.
Lawyers and tax professionals in each jurisdiction can help you understand local inheritance taxes, forced heirship rules, reporting requirements and probate procedures.
Steps to take:
Start with your country of residence and any country where you hold property.
Ask each adviser about cross-border implications and how local laws interact with foreign wills.
Use advisers who regularly work with expats, as they are more familiar with multinational estates.
Example: A person living in Canada with rental property in Cyprus may need legal advice in both countries. The Canadian adviser can confirm how the estate will be taxed domestically, while the Cypriot lawyer can explain local inheritance rules and whether a separate Cypriot will is necessary.
5. Decide Whether You Need Single or Multiple Wills
After receiving legal guidance, the next decision is whether one international will is sufficient or whether separate wills are required in each jurisdiction. The right approach depends on where your assets are held and how each country treats foreign wills.
General guidance:
Single will: Suitable if you have minimal foreign assets or if local laws recognise a foreign will without restrictions.
Multiple wills: Often recommended when you own real estate abroad, as property usually follows the laws of the country where it is located.
Important: Multiple wills must be drafted carefully to ensure they do not revoke one another.
Example: A person living in the UAE who also owns a home in Ireland may have one UAE-specific will registered with the local courts and another Irish will covering property within Ireland. When drafted properly, each applies only to the assets in its respective country.
6. Consider Additional Planning Tools: Gifts, Trusts, Charitable Legacies, and Lifetime Transfers
To enhance your succession plan, it can be helpful to use strategies that go beyond traditional wills. These tools may reduce tax liability, provide greater control, or streamline asset transfer.
Options to explore include:
Lifetime gifts: Reducing your taxable estate by giving assets away earlier.
Trusts: Allowing you to appoint trustees to manage assets on behalf of your beneficiaries.
Charitable gifts: Potentially reducing inheritance tax while supporting causes you care about.
Life insurance: Offering quick liquidity to cover taxes or expenses.
Example: A parent with adult children may gradually gift savings or investments over several years, reducing the value of their taxable estate while helping their children financially during their lifetime.
7. Review and Update Plans Regularly
Even the best-executed succession plan can become outdated if it is not reviewed regularly. Life events such as marriage, divorce, moving countries or purchasing a new property abroad can all impact your estate plan. Therefore, reviewing your documents ensures alignment with your current goals and circumstances.
What to keep updated:
Wills in all jurisdictions
Beneficiary designations on pensions, insurance and investment accounts
Trust documents
Asset inventory and ownership details
Example: If someone relocates from Qatar to Spain, their existing will may remain valid, but their new residency may trigger local inheritance rules, making a review essential.
8. Communicate With Your Loved Ones or Executors
Finally, a succession plan is only effective if the people responsible for carrying it out know what it entails. Transparently communicating your intentions helps avoid confusion, delays and stress for your beneficiaries.
What to communicate:
The existence and location of all wills
Who the executors are and what their roles involve
Where important documents and account details are stored
Any special wishes or instructions
Example: Someone with property in Thailand and investments in the UK might give their executor secure access to a digital vault containing copies of deeds, statements and legal documents, ensuring that the administration process begins smoothly and without uncertainty.
A Realistic Example: How One Expat Follows the Succession Planning Roadmap
To help illustrate how these steps work in practice, let’s look at a realistic example of an expat navigating the full succession-planning process. Although fictional, this scenario reflects common situations many expats face.
Meet David: A British Professional Living Abroad
David is a 52-year-old British national who has lived in Singapore for the past 11 years. He is married, has two adult children living in the UK, and owns assets in multiple countries, including a rental flat in Manchester, savings and investments in Singapore, and a pension held in the UK.
Although financially comfortable, he has never fully addressed how his cross-border estate would be managed.
As he begins looking toward retirement, he decides it’s time to plan properly.
Step 1: Listing His Global Assets and Liabilities
David starts with an inventory of everything he owns. He lists his Manchester flat, his Singapore condominium rental deposit, a UK ISA, a globally diversified investment portfolio held through an international brokerage account, several local bank accounts, and his defined contribution pension in the UK.
He also includes liabilities: a small, remaining mortgage on the Manchester property and a personal loan he took when first moving abroad.
Why this helps: Having the full picture gives David clarity on where his assets sit, their value, and which jurisdictions are involved. This is essential before he takes any further steps.
Step 2: Recording Each Asset’s Location and Ownership
Next, David notes the ownership structure of each asset. The Manchester flat is in his sole name; his Singapore savings account is a joint account with his spouse; his international investment portfolio is individually owned; his UK pension has chosen beneficiaries.
What he discovers: He learns that the UK property will always be subject to UK rules and potential inheritance tax because it is UK-situs. Meanwhile, his Singapore cash accounts will follow local probate rules, unless he puts measures in place.
This illustrates why ownership and location matter so much for expats.
Step 3: Reviewing Residency History and Tax Exposure
David then reviews his UK residency status. Because he lived in the UK for more than 10 years of the previous 20, he realises that his worldwide estate may still fall under the UK’s long-term residency inheritance tax rules, depending on when he eventually leaves Singapore.
His conclusion: He sees the importance of planning early to avoid unnecessary UK inheritance tax, particularly as his global estate is likely to exceed standard UK thresholds.
Step 4: Speaking With Legal and Tax Advisers in Each Jurisdiction
David books consultations with a UK solicitor, a Singapore lawyer and a cross-border tax specialist.
The UK solicitor explains how his UK pension and property will be taxed and how a UK will should be drafted.
The Singapore adviser explains local rules on bank accounts and probate, and confirms that certain accounts can be transferred more easily if he uses specific nomination forms.
The tax specialist helps him model his exposure to UK inheritance tax based on residency timelines and potential moves in the future.
Result: David now understands the interplay between UK and Singapore rules, particularly around domicile, residency, and IHT exposure.
Step 5: Deciding On Single or Multiple Wills
Based on legal advice, David decides to have:
A UK will covering his UK property, ISA, and pension nominations
A Singapore will covering all Singaporean bank accounts and cash assets
His advisers ensure that neither will revokes the other.
Reasoning: Two wills allow for faster, country-specific probate and clearer distribution instructions. This avoids the long delays that can arise when a single will must be interpreted across multiple jurisdictions.
Step 6: Using Trusts, Gifts and Other Planning Tools
Next, David considers lifetime planning options. His solicitor recommends a trust for part of his international investment portfolio to ring-fence it from potential future UK inheritance tax exposure.
He also chooses to gift a portion of his cash savings to his children now, as they are buying their first homes. These gifts may help reduce the value of his taxable estate in the long term, depending on future UK tax rules.
Example of his reasoning: The trust allows him to keep long-term oversight of his investments while reducing tax exposure; the gifts allow him to see his children benefit today, while potentially lowering future estate taxes.
Step 7: Reviewing and Updating The Plan
David commits to reviewing his wills, trust documents and beneficiary nominations every three years or sooner if he relocates or his family circumstances change. He also adds a calendar reminder for this review.
Why this matters: He wants to ensure his estate plan keeps pace with potential moves (such as returning to Europe), changes in tax law, and any updates to his asset structure.
Step 8: Communicating his wishes clearly
Finally, David meets with his spouse and adult children to explain where his documents are stored, who the executors are, how assets are structured and what his intentions are. He also provides his executors with a secure digital folder containing essential information.
End result: His family now has clarity and reassurance and will be far better equipped to handle administrative matters when the time comes.
Why Working With a Professional (and Global-Minded) Adviser Matters
As someone who has lived and worked internationally and specialises in wealth management for expats, I know first-hand the challenges of navigating multiple legal systems, tax regimes and cross-border arrangements. A professional adviser can:
Help you interpret local and home-country laws side-by-side.
Assist in structuring wills/trusts that are valid and effective in all relevant jurisdictions.
Provide tailored strategies: combining gifts, trusts, wills, charitable giving, pension-nominations, to reflect your personal values, family circumstances and long-term goals.
Keep you up to date since laws change, and what was optimal years ago may no longer apply today (as the 2025 UK IHT reform shows).
I adopt a pragmatic and proactive approach, believing collaboration leads to the best results. With careful planning, you don’t just protect your wealth, you ensure that your legacy is passed on to those you care about, and in the manner you intend.
Take the Next Step in Protecting Your Legacy
Succession planning for expats can feel complicated. But it’s also among the most important financial decisions you’ll ever make.
If you are living abroad and if you maintain connections to your home country, I encourage you to start sooner rather than later.
If you would like a second opinion (or a first!) I am always happy to offer a free 30-minute, no-obligation consultation.