International Inheritance Lawyers
Specialist advice on cross-border estates, foreign assets and succession.
Navigating inheritance where more than one country is involved.
When assets, family members or domicile connections span more than one country, inheritance planning and estate administration become significantly more complex.
Different legal systems apply different succession rules. Tax regimes vary. Forced heirship rules in some jurisdictions can override personal wishes. Without careful planning, families can face double taxation, conflicting claims or costly delays.
Our international inheritance lawyers advise individuals, families and business owners with cross-border estates, liaising with overseas lawyers to ensure English estate planning works alongside local rules.
We are based in London and the South East and regularly act for clients with property, investments and family connections across Europe, the Middle East, the United States and further afield.
When do you need international inheritance advice?
You may need specialist advice if:
- You own property or assets abroad.
- You are non-UK domiciled but live in England.
- You have dual nationality.
- You expect to inherit from someone overseas.
- You are administering an estate with foreign assets.
- You have family members living in different jurisdictions.
- A foreign will exists alongside an English will.
Call us on 0808 2562 917 or
Understanding domicile, residence and succession law.
One of the most important questions in any international inheritance matter is domicile.
Domicile is not simply where you live. It is a legal concept that affects:
- Which country’s succession rules may apply.
- Whether worldwide assets fall within the scope of UK inheritance tax.
- How tax treaties operate.
- Whether foreign forced heirship provisions could apply.
We provide clear guidance on how English law approaches domicile and how it interacts with overseas systems. Where appropriate, we work closely with trusted advisers in other jurisdictions to ensure joined-up advice.
The risks of not planning international inheritance tax effectively
Without careful planning, cross-border estates can face a range of avoidable risks, including:
- Double taxation, where the same assets are taxed in more than one jurisdiction.
- Unexpected inheritance tax exposure if worldwide assets fall within the UK tax net.
- Loss of available reliefs or exemptions due to differences between tax systems.
- Conflicting legal rules around domicile, residence or asset location.
- Reporting errors or missed deadlines when dealing with HMRC or foreign authorities.
- Delays in administering the estate while tax positions are clarified across jurisdictions.
Our private client solicitors advise on managing these risks by analysing the scope of UK inheritance tax, considering the interaction with foreign tax regimes and identifying planning opportunities that reduce the likelihood of double taxation.
Early advice helps ensure cross-border estates are structured carefully, with tax obligations understood and reporting handled correctly.
Call us on 0808 2562 917 or
Cross-border estate planning and specialist advice.
Our private client team advises individuals, families, business owners and international clients whose estates extend beyond a single country. Our work commonly involves:
- Coordinating separate wills across multiple jurisdictions.
- Assessing inheritance tax exposure in more than one country.
- Using trusts where appropriate.
- Planning for business or property interests held abroad.
- Identifying potential forced heirship rules.
Meet our team
Speak with our international inheritance solicitors.
Cross-border estates can raise complex legal and tax questions. Taking advice early helps ensure assets in different jurisdictions are protected and your estate is structured with clarity.
Whether you are planning ahead, reviewing existing arrangements or administering an estate with overseas assets, we provide careful, coordinated advice tailored to your circumstances.
Contact Thomas Mansfield Solicitors to arrange a confidential discussion about your cross-border inheritance matters.
Frequently asked questions
Can my estate be taxed in more than one country?
Yes, this can happen. The UK may tax worldwide assets depending on domicile status, while another country may tax assets located within its borders. Double tax treaties can reduce duplication, but they do not always eliminate it entirely. Coordinated advice is essential to understand which jurisdictions have taxing rights and how to structure matters efficiently to minimise exposure and ensure compliance.
Do I need a separate will for assets held abroad?
Possibly. In some jurisdictions, a separate local will can simplify administration and reduce delay. However, it must be carefully coordinated with your English will to avoid accidental revocation or conflicting provisions. In other cases, a single well-drafted English will may be sufficient. The right approach depends on the location of assets, their value and the succession rules that apply. Proper coordination ensures clarity for executors and beneficiaries.
How does probate work when foreign assets are involved?
Administering an estate with overseas assets usually takes longer than a purely domestic estate. Executors may need to obtain recognition of an English grant abroad or apply for a separate foreign grant. Additional documentation, translations and local legal advice are often required. Early identification of international assets and proactive coordination with overseas advisers can significantly reduce delay and administrative complexity.
I live in England but own property overseas. What should I consider?
You should consider how that property will pass on death, whether local succession rules apply and whether local inheritance or estate taxes may arise. It is also important to ensure your English will addresses overseas assets appropriately. Where property is held through a company or other structure, additional considerations may arise. Early advice helps ensure that your estate plan reflects both English law and the rules of the relevant jurisdiction.
What are forced heirship rules and could they affect me?
Some countries have mandatory succession rules requiring part of an estate to pass to specific family members, regardless of the terms of a will. These provisions can apply based on nationality, residence or the location of assets. They may limit testamentary freedom and override intended arrangements. Understanding whether forced heirship could apply allows for informed planning and reduces the risk of later disputes.
What is domicile and why is it important for inheritance tax?
Domicile and tax residency are legal concepts that affect both succession law and tax. It is not simply where you live or hold nationality. Your domicile status can determine whether UK inheritance tax applies to your worldwide assets and whether foreign succession rules may affect your estate. Long-term residence in England can also have tax consequences. Understanding your domicile position is often the starting point for effective cross-border estate planning.
Contact us
Getting in touch couldn’t be easier. Use our form or call us to speak to an experienced solicitor in confidence.
Please note we cannot offer legal aid.