The Expat Estate Planning & Inheritance Guide
Make it clear what happens to your wealth, wherever it is held
When your family and assets span several countries, an estate plan needs to do more than name who inherits.
Your wills, pensions, investment accounts, property ownership and beneficiary nominations should work together. The people dealing with your estate need to know what exists, where it is held and whom to contact.
This guide helps you:
- Identify the documents and decisions that need reviewing
- Understand where cross-border tax and legal questions can arise
- Make it easier for your family to locate and deal with your assets
What's in the guide?
Why an expat estate plan needs more than a will
A will is important, but it cannot answer every question an international family may face.
You may live in the Middle East, own a UK property, hold US investments and intend to retire in Europe. Your spouse may have a different nationality. Your children may live in another country again.
If you die or lose capacity, your family needs to establish which documents apply, who has authority to act and how to access each asset. Different countries and providers may require different evidence before releasing funds.
Ownership can change what happens
An asset held in your sole name may be dealt with differently from one held jointly, through a company or in trust. Pension death benefits and life insurance may follow their own nomination and policy rules.
Start by recording how each asset is owned, rather than assuming the will directs everything.
Residence history can matter after you leave
Moving away does not necessarily end UK inheritance tax exposure on worldwide assets. The UK’s residence-based inheritance tax rules look at a person’s history of UK residence and can continue to apply for a period after departure.
Your position needs checking against your own dates and circumstances. It should not be inferred solely from your current address.
Pensions need particular attention
A pension beneficiary form should be reviewed after marriage, divorce, the birth of a child or a significant change in family circumstances.
The tax treatment also changes over time. From 6 April 2027, most unused UK pension funds and pension death benefits are due to be included in the value of a deceased person’s estate for inheritance tax purposes. That makes it particularly important to review pension and estate planning together.
US assets may create a separate issue
A person does not have to live in the United States or be a US citizen for US estate tax rules to become relevant. Certain US-situated assets owned by a nonresident who is not a US citizen can bring an estate within US filing rules.
The asset itself, its ownership and any applicable treaty need reviewing before assuming that a non-US address settles the position.
The practical burden matters too
Even a technically sound plan can be hard to carry out if no one knows where the accounts are or who holds the documents.
Your family should be able to find a current asset list, professional contacts, insurance details, relevant wills and instructions for accessing important records. Keep passwords and sensitive credentials in an appropriate secure arrangement rather than placing them in the will.
Who is this guide for?
This guide is particularly useful if you:
- Live abroad but own property or investments in your home country
- Have pensions and investment accounts in several jurisdictions
- Own US assets or have a US citizen in your family
- Have a spouse or children with different nationalities or countries of residence
- Have written a will in one country but since acquired assets elsewhere
- Own a business or hold assets through a company or trust
- Have recently married, divorced or had children
- Are deciding where to retire
- Want your family to know what to do if you die or lose capacity
The aim is to help you prepare the right questions for qualified legal and tax advisers in the countries that matter to your estate.
The five-part estate plan check
A useful estate review follows the path your family would have to take.
1. Find it
Can someone you trust identify every significant asset and liability?
Maintain an up-to-date inventory showing the provider, country, account type, ownership and a contact point. Include property, pensions, insurance and business interests.
2. Control it
Who has legal authority to act if you lose capacity or die?
Review your wills, executors, trustees, guardians and powers of attorney with appropriately qualified lawyers. A document made for one jurisdiction may not solve an issue elsewhere.
3. Receive it
Who is expected to inherit each asset?
Compare your wishes with pension nominations, insurance beneficiaries, account designations, joint ownership and the terms of any trust. Identify conflicts before your family has to deal with them.
4. Tax it
Which countries could tax the estate, the transfer or the beneficiary?
Review the position country by country. Citizenship, residence history, the location of assets, the type of asset and treaty provisions can all matter. Do not assume one country’s tax treatment answers another’s question.
5. Carry it out
Could your chosen people administer the plan in practice?
Think about access to records, the language of documents, likely costs, where executors live and whether there will be enough accessible cash to meet expenses while the estate is settled.
The test is simple: if something happened to you tomorrow, would the right people know what exists, what you want and how to begin?
Frequently asked questions
Do expats need a will in every country where they own assets?
Not necessarily. The right arrangement depends on the countries, the assets and the laws involved. If you have more than one will, lawyers should check that they work together and that a later document does not unintentionally revoke an earlier one.
Does my UK will cover property and accounts abroad?
It may address some overseas assets, but whether it is effective and practical depends on the relevant local law and how the asset is owned. Have it reviewed by lawyers familiar with the jurisdictions involved.
Am I outside UK inheritance tax once I leave the UK?
Not necessarily. UK assets can remain relevant, and your previous years of UK residence may bring non-UK assets within scope for a period after you leave. Your residence history and the nature of each asset need checking.
Will my pension automatically go to the person named in my will?
Do not assume so. Pension schemes have their own death benefit rules and nomination processes. Check the scheme documents and keep your beneficiary wishes current.
Can a non-American expat face US estate tax?
Potentially. Certain US-situated assets owned by someone who was neither US-resident nor a US citizen at death can fall within US estate tax rules. The asset type, ownership and any treaty relief should be reviewed.
What should I do first if I have never made a cross-border estate plan?
List your assets, where they are held and how they are owned. Gather existing wills, powers of attorney and beneficiary nominations. Then have the documents and tax position reviewed by appropriately qualified professionals in the relevant countries.
About Josh Clancey
Josh Clancey is a Private Wealth Adviser and Regional Head of Technical at Skybound Wealth. He specialises in pensions and retirement planning for internationally mobile professionals.
His work brings together pensions, investments, tax, currency and estate planning so clients can understand how decisions in one country affect the wider picture. He also works alongside legal and tax specialists when a client’s circumstances call for advice in multiple jurisdictions.
Finance with JC provides educational information. Wills, powers of attorney and jurisdiction-specific legal or tax questions require advice from appropriately qualified professionals.