Wealth · Private Clients

Inheritance Tax Planning

Your inheritance and estate tax exposure mapped across countries, then reduced with gifts, trusts, insurance and planning around where you're domiciled.

Overview

Estate tax is first a question of which countries can tax you, then a planning question. A tax bill can come from your domicile, where you live, your citizenship, where an asset physically is, and where the company holding it is registered — and two or more countries can each claim the right to tax the same asset.

We map your exposure first: every asset, where it legally sits, which countries' rules reach it, at what rate, and what relief or treaty reduces the double charge. Only then do we look at gifts, trusts, changing how assets are owned, insurance and domicile planning to reduce it.

Having the cash to pay is part of the answer. An estate can be well planned and still force the family to sell a business or a home because the tax is due before the assets can be sold, so the plan sets out who pays, from where, and by when.

Pensions are looked at alongside the rest of the estate. A QNUPS (Qualifying Non-UK Pension Scheme — paid into with already-taxed money, and unable to receive a UK pension transfer) can be right when allowances are already used and the aim is genuinely saving for retirement. We judge it on substance, not as a convenient inheritance tax wrapper; if a UK pension scheme is involved, that belongs with our UK pension transfer work instead.

What's included

What we do for you

  • What your estate would owe, country by country
  • Gifting and trust options
  • Cash ready to pay the tax bill
Who it's for

Who usually uses this

  • People with UK domicile, or treated as UK-domiciled, who live abroad
  • Families owning property or assets in several countries with estate taxes
  • Non-doms and people moving back home, planning around changes in where they live
  • Business owners passing shares to the next generation
How we work

One team, step by step, from the first call to handing it over.

01 · Mapping the exposure

Your assets, where they sit, your domicile, residence and citizenship mapped against every country that could tax your estate.

02 · Working out the bill

Projected tax calculated country by country, with treaty relief and exemptions applied.

03 · Reducing it

Gifts, trusts, changing how things are owned, insurance and domicile options compared, with their costs and what they tie you into.

04 · Paperwork

Wills, trust deeds, beneficiary nominations and letters of wishes lined up across countries and filed.

Deliverables

What you receive.

Every engagement closes with a specialist-reviewed handover pack — retained on file for thirty years.

  • A map of what your estate is exposed to, country by country
  • The projected inheritance and estate tax, worked out
  • A report on ways to reduce it, with the trade-offs
  • A plan for having the cash to pay the bill
  • Wills, trusts and nominations coordinated across countries
Where we do this

The countries we most often use for this service.

United Kingdom
Ireland
France
Spain
United States
UAE
Jersey
Guernsey
Frequently asked

Questions we hear on every intake call.

Am I still exposed to UK inheritance tax if I live abroad?
Very possibly. UK inheritance tax follows long-term residence and domicile status, not just where you live now, and UK assets such as property stay taxable wherever the owner lives.
Do trusts still work for estate planning?
Yes, for the right assets and the right family, but they're no longer a simple exemption. Charges when assets go in, every ten years and when they come out, plus reporting and where the settlor lives, all decide whether a trust actually helps.
Can two countries tax the same estate?
They can. Where the two countries have an estate tax treaty, relief is usually available; where they don't, credit for the other country's tax may be limited, and planning the structure matters more.
When should we start?
Before a move, a sale or a gift — most reliefs depend on living for a set period after the event. Planning after the event is far more limited.
Does a QNUPS reduce UK inheritance tax?
It can, when it's a genuine retirement plan paid into with already-taxed money and the amounts fit your circumstances. It's not a wrapper for sheltering an estate, it can't receive a transfer from a UK registered pension, and paying in too much invites challenge. We judge it on substance alongside the rest of your estate plan.
Ready to start?

Start with a twenty-minute call. Come away with a written plan and price.

Every engagement begins with our advisory team and is assigned to the relevant specialists. Fees are quoted in writing before any work begins. No hourly billing.