Securing Your Legacy: Listen to our Panel Recording

A recap of our cross-border wealth planning panel evening, held on 21st May 2026 at Domitys, Bangsar with Fusion Partners and API Global.

By Jamie Bubb-Sacklyn

Recently, four specialists gathered to tackle one of the most underaddressed challenges facing internationally mobile individuals: what happens to your wealth when your life spans borders, and your plan doesn't.

Hosted by Jamie Bubb-Sacklyn of Melbourne Capital Group, the panel brought together Anthony Rogers of Fusion Partners, Daniel Earl of API Global, and Matthew Green of Melbourne Capital Group Enterprise. The conversation that followed was frank, practical, and at times quietly sobering. A reminder that for globally mobile families, the cost of leaving things unjoined tends to show up at the worst possible moment.

Who Was in the Room

Before the panel began, Jamie asked three questions of the audience. The responses set the tone for everything that followed.

Most hands went up when asked whether attendees held assets in more than two jurisdictions. Most went up again for those married to someone of a different nationality. And almost all went up for those planning to retire somewhere different to where they are today.

The point was made without needing to be stated: generic financial advice, built around a single country and a single life stage, simply doesn't fit the people in that room.

The Estate Planning Reality

Anthony Rogers opened with a distinction that reframed the conversation immediately. Estate planning, he explained, is not just about tax. In the UK, where inheritance tax sits at 40%, the focus has historically been almost entirely on reducing that liability. But travel to Malaysia, Singapore, or much of Southeast Asia, where inheritance tax doesn't exist, and the conversation shifts entirely to something more fundamental: making sure your assets reach the right people, in the right way, at the right time.

"It's about setting up your legacy," Anthony said. "And a big part of that is not just about what happens when you die, it's about what happens during your lifetime."

The practical implications of getting this wrong are significant. Anthony walked the room through an example: a British national who had lived in Malaysia for 20 years, with assets in the UK, Malaysia, and the Isle of Man. He had been sensible enough to have two Wills: one covering Malaysian and Singaporean assets, one covering everything else. But the absence of a separate UK Will and an Isle of Man Will had created a chain of delays that added months to the probate process and created complications that could easily have been avoided.

The lesson, Anthony said, is straightforward: if you hold assets in multiple countries, you need a Will for each jurisdiction, or at minimum, Wills that will be formally recognised there. "It's a lot easier if you have a specific Will covering your specific assets in that specific country."

One important nuance emerged from audience questions: the jurisdiction of a Will does not determine the inheritance tax treatment of the assets it covers. A Will drafted in Malaysia covering Malaysian assets does not bring those assets into the scope of UK inheritance tax. The two issues: legal succession and tax liability, run in parallel but are treated separately.

When a Will Isn't Enough, and When It Isn't Needed

The conversation moved to a point that surprised some in the room: not all assets require a Will at all.

Jamie noted that certain investment platforms and insurance structures offer built-in beneficiary trust arrangements. When an asset is held within such a structure, it falls outside the probate process entirely, passing directly to named beneficiaries upon death, regardless of jurisdiction. Anthony added that pensions work similarly. Most pensions, whether UK or international, are held in trust and fall outside the probate process, provided beneficiaries have been properly nominated.

This matters considerably in light of one of the most significant legislative changes on the horizon. From April 2027, UK pensions will be brought into scope for UK Inheritance Tax for the first time. Historically one of the most tax-efficient vehicles for passing on wealth, pensions held by UK taxpayers above the nil-rate band threshold will now potentially face a 40% charge.

For British nationals living in Malaysia, Jamie outlined a route worth exploring: under the double tax agreement between the UK and Malaysia, pension income can be drawn down and taxed in Malaysia rather than the UK. Given that Malaysia does not tax personal income in this way, and with no capital gains tax and no inheritance tax on non-UK assets for those who have been outside the UK for at least ten years, the implications for long-term pension planning are material.

"We're going through that process for clients right now," Jamie said. Drawing pension assets out of the UK tax environment, reinvesting them on an offshore platform, and restructuring them in a far more favourable position.

The New Geography of Tax Planning

Matthew Green took the floor next, and his opening observation captured something that has shifted meaningfully in the residency and citizenship space over the past few years.

Historically, Matthew explained, his clients were people with limited passport strength. Individuals seeking mobility, visa-free access, and the ability to move freely. That demographic has changed. Today, he is working with growing numbers of American clients driven by political polarisation at home, and increasing numbers of British nationals who, having understood the implications of the UK's shift from a domicile-based to a residence-based inheritance tax system, are asking a different question entirely: where can I retire and pay significantly less?

The removal of the non-domicile regime in the UK, replaced by a residence-based framework under which anyone who has been UK resident for ten of the last twenty years is considered long-term resident and subject to inheritance tax on worldwide assets, has brought urgency to conversations that previously felt theoretical.

Matthew walked through several jurisdictions that are drawing serious interest. Portugal retains its Golden Visa programme and, while its income tax regime is broadly comparable to the UK's, its inheritance tax, officially termed stamp duty, stands at 10%, falling to zero for transfers to spouses, children, grandchildren, or parents. Italy offers a compelling flat tax regime for retirees who relocate to towns with fewer than 30,000 residents: 7% on all worldwide income brought into the country, with inheritance tax exempt up to one million euros per descendant and only 4% above that threshold. Turkey has entered the conversation more recently, offering citizenship by investment through property purchase at $400,000, alongside a newly announced regime providing full exemption from income tax, capital gains tax, and inheritance tax for twenty years.

Cyprus, meanwhile, offers something unusual: tax residency in as few as 60 days, provided the individual does not spend 183 days in any other single country. For those holding significant unrealised gains in cryptocurrency, a growing segment of Matthew's client base, Cyprus and Portugal both offer zero capital gains tax on crypto assets held beyond a qualifying period. "The demographic has changed dramatically in just two or three years," Matthew observed. "From mobility to tax planning."

[Request panel recording]

This recap covers the first half of the evening's discussion. The full conversation including Daniel Earl's session on building a diversified retirement portfolio, the Thailand property market, and the panel's closing Q&A, is available in the recording above. We'd encourage you to listen to it in full.

Take the Next Step

The questions raised on the night about Wills, structures, residency, and tax don't have one-size-fits-all answers. What they do have is a starting point: a conversation with the right people. If you'd like to explore what a joined-up cross-border plan looks like for your circumstances, we're ready to help.

Contact us at info@melbournecapitalgrup.com or connect with me, Jamie Bubb-Sacklyn on Linkedin.