How to Estate Plan When Wealth Spans Borders

Over the next two decades, an estimated $83 trillion is expected to change hands in what’s being dubbed the ‘Great Wealth Transfer’. Scale aside, what makes this transfer different is the inherent complexity, in part because today’s wealth is more likely to be global.

Globalisation has made cross-border wealth the norm rather than the exception. According to BCG's Global Wealth Report 2026, cross-border wealth rose 8.4% to $15.7 trillion in 2025, driven partly by demand for geographic diversification and geopolitical fragmentation. Lifestyle also plays into this, it’s not uncommon for parents retire in one country while holding assets in several others. Or for children studying abroad to settle there permanently. Meanwhile, multinational marriages and dual citizenships have also become commonplace.  

The problem is, while families and assets may span borders, few have planned for how that wealth crosses those borders at the moment of transfer.

Inheritance rules differ country-to-country 

One of the reasons people fail to plan is due to an assumption that inheritance rules are broadly similar everywhere; they're not. To offer context, some countries impose forced heirship rules; this means that a fixed portion of an estate must go to specific relatives regardless of what’s in the will.  

Then there’s taxes. While some countries do not have inheritance tax at all others levy 40% or even 55%. The way countries impose taxes is also different, some impose it on the deceased’s estate, while others levy inheritance taxes on beneficiaries. Tax rules also change, for instance the UK recently overhauled its rules around inheritance tax.  

The risk for cross-border families is double taxation. Unlike income tax, inheritance taxes are covered by relatively few international treaties so there’s little relief. This means that without careful planning the same asset may be taxed twice. This can obviously impose serious financial strain, but additionally, as taxes usually come with a deadline, heirs may be forced to sell illiquid assets quickly and possibly unfavourably, simply to meet their tax obligations.  

What can families do? 

The Great Wealth Transfer is happening and families that are prepared will be better positioned to preserve their wealth and their legacy. But what does preparation look like?

Know where the money is

It may sound obvious, before anything else, list every jurisdiction connected to your estate. So that includes; where you're a resident, where you're domiciled or hold nationality, where any property, investments, or business interests sit, and where your heirs live. Each one may apply a different test (residence, domicile, nationality, or simply asset location) to decide whether it has a claim over part of your estate. Our estate planning checklist walks through this jurisdiction-mapping exercise in more detail.

Have a will that’s recognised in every relevant jurisdiction  

It’s worth noting that a will is not an estate plan, although it constitutes a vital element. It’s also important to understand that a single will rarely works cleanly across borders. Because a single will from one jurisdiction isn't automatically honoured elsewhere, and in civil-law countries, local succession law can override foreign will instructions for assets located there. The more reliable approach is usually a separate, properly executed will for each jurisdiction, or a coordinated set of wills drafted to work together.  

It's also worth remembering that the jurisdiction of a will doesn't determine the tax treatment of the assets it covers. Succession and tax liability are separate questions that need separate answers, a point covered in detail during our recent panel recording on cross-border wealth planning. I explore this in more depth in the second instalment of my Substack series on the Great Wealth Transfer, which looks specifically at cross-border succession planning.

Get ahead of taxation 

Because so few treaties cover inheritance tax specifically, the same asset can be taxed twice: once based on the deceased's residence or domicile and again based on the heir's residence or the asset's location. However, through planning and wealth restructuring; using a combination of jurisdiction planning, trust or holding structures, gifting and timing, a tax burden can be reduced.  

For more on how restructuring works, you can watch a video with one of our Private Wealth Managers exploring a scenario involving a UK expat couple reducing their inheritance tax burden from hundreds of thousands of pounds to just £26,000.  

Build liquidity into the plan 

Tax authorities generally expect payment within a fixed window, regardless of how liquid the estate is. If wealth sits mainly in property, a private business, or long-term investments, heirs can be forced into a rushed sale on unfavourable terms to meet a deadline.  

Reviewing how much of an estate is liquid, and whether structures like trusts, gifting, or life insurance could cover a tax bill without a forced sale, is a core part of restructuring for cross-border families.

Have the difficult conversation

Preparation isn't only structural; heirs need to be prepared. A recent study from Kiplinger, where it surveyed 5,156 Americans, revealed two in five families have never discussed inheritance plans. For a family with assets in one country, that's a planning gap. For a family with assets spread across multiple countries, it's a significant structural risk.  

Heirs who've never discussed what they're inheriting, in what form, or under what obligations, arrive at the point of transfer unprepared both emotionally and practically. This is a bigger risk for cross-border families, since heirs may also be inheriting foreign reporting obligations they don't know exist. So regardless of how uncomfortable it may be, it’s worth having the difficult conversation with heirs now to avoid possibly costly disputes and delays later.  

A good first step is simply sharing with loved ones where assets are held and how to access them. You can check out our helpful guide how to get your finances in order.

Review and amend

Laws, tax regimes, and family circumstances are always shifting. So, a plan that was sound five years ago may no longer be fit for purpose. It’s good practice to treat estate planning as a living strategy rather than a single document that’s filed away and forgotten about.

Co-ordination is key – speak to an expert 

Because of the inherent complexities and shifting landscape around inheritance rules, it’s worth seeking expert advice. When consulting with experts, it's also good to find a firm that specialises in cross-border estate planning and who can draw together a team of experts. Hubbis' Wealth Management Forum discussion on succession planning touched on this, with panellists agreeing seamless international collaboration between advisers being a requirement.  As a successful cross-border estate plan is the result of a coordinated exercise across law, tax, and family communication.

Preparation to promote protection

The Great Wealth Transfer will not be managed successfully by default. For international families, preserving a legacy means understanding where assets and heirs are located, anticipating how different legal and tax systems may interact, and putting a coordinated plan in place before it is needed. Starting early creates more options, reduces the risk of forced decisions, and gives the next generation the clarity and confidence to manage what they inherit.

You can read more about cross-border estate planning as part of Chris’ series on the Great Wealth Transfer on his Substack.

If your wealth, family, or assets span more than one country, connect with Chris on Linkedin or speak to one of our Private Wealth Managers to talk through where your plan currently stands.

This article is for general information only and does not constitute financial, legal, or tax advice. Rules on inheritance, tax, and reporting vary by jurisdiction and are subject to change; independent, professional advice should be sought before making any decision based on individual circumstances.

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