Cross-Border Estate Planning
For individuals with assets, family members or business interests spread across more than one country, estate planning is rarely straightforward. The interaction between different countries' inheritance tax regimes, succession laws and treaty provisions creates a level of complexity that requires specialist advice — and planning that is put in place well before it is needed.
UK Inheritance Tax for International Clients
The UK introduced a new residence-based inheritance tax regime in April 2025, replacing the previous domicile-based system. Under the new rules, individuals who have been UK resident for 10 out of the last 20 years are subject to UK IHT on their worldwide assets — regardless of where those assets are located or where the individual was born.
For individuals who are not long-term UK residents, UK IHT applies only to UK situs assets — which includes UK real estate, regardless of how it is held. This means that non-UK resident investors with UK property have a UK IHT exposure that needs to be addressed as part of their overall estate planning.
The Interaction Between UK and Overseas Succession Rules
Many of our clients come from jurisdictions — including Italy and other European countries — where forced heirship rules apply, requiring a proportion of an estate to pass to certain family members regardless of the terms of a will. Where an individual has assets in both the UK and a forced heirship jurisdiction, careful coordination between the two legal systems is essential to ensure that their wishes are respected and that the overall tax burden is minimised.
Wills and Cross-Border Succession
Having a UK will does not automatically deal with assets held overseas, and an overseas will does not automatically deal with UK assets. For individuals with a truly international estate, a coordinated approach to wills — taking into account the succession rules of each relevant jurisdiction — is essential.
Trusts and International Structures
Trusts remain an important planning tool for individuals with international estates, though the rules governing their UK tax treatment have become increasingly complex. For individuals coming to the UK, the timing of when a trust is established and how it is structured can have significant long-term consequences — both during the individual's lifetime and on death.
How Laggan Can Help
We advise internationally mobile individuals and families on all aspects of cross-border estate planning — from UK inheritance tax exposure and will planning to trust structuring and the interaction with overseas succession regimes. We work closely with overseas lawyers and advisers where needed to ensure a coordinated approach across jurisdictions.
If your estate spans more than one country, speak to us about putting the right structure in place.
