& : Expat Inheritance Tax Guide: What Every Internationally Mobile Family Needs to Know

Yes — this is common and widely underestimated. Multiple countries can simultaneously claim the right to tax the same estate. The deceased’s domicile triggers worldwide scope. The location of assets triggers situs-state tax. The heir’s residence triggers heir-side inheritance tax in France, Germany, Netherlands, Belgium, and Japan. No single international rule prevents this. Relief depends on bilateral tax treaties — which exist for only a minority of country pairs, and even where they exist, provide only partial relief when the regime types differ.

Yes — for up to 10 years after leaving. From April 2025, the UK Long-Term Resident test replaced domicile-based IHT. Anyone with 10 or more qualifying UK tax years carries a departure tail of 3–10 years after leaving (3 years for 10–13 years of UK residence; 10 years for 20+ years). During this period, UK IHT at 40% above the nil-rate band applies to worldwide assets — regardless of where you now live. Moving to Spain, UAE, Australia, or any nil-tax jurisdiction does not shorten this window.

Five countries tax their resident heirs on worldwide assets received — regardless of where the deceased was domiciled or where the assets are. France (6 of prior 10 years of French residence), Germany (current German residence), Netherlands (current Dutch residence), Belgium (current Belgian residence), and Japan (Japanese domicile or nationality within 10 years). A French-resident child inheriting from an Australian parent with no French assets faces French succession tax on the entire worldwide inheritance under art.750 ter §2. This trigger is entirely independent of every other planning decision and is the most systematically missed rule in cross-border estate planning.

Yes — the US imposes estate tax on the worldwide estate of all US citizens above $15 million (2026, made permanent by the One Big Beautiful Bill Act). This applies regardless of where a US citizen lives, where their assets are located, or how long they have been abroad. No treaty removes this — every US bilateral estate tax treaty contains a citizenship carve-out. Moving to UAE, France, Australia, or Mexico does not reduce US estate tax exposure.

Not immediately. UAE has no inheritance tax. But home-country departure tails continue during UAE residence: UK nationals carry a departure tail of 3–10 years; German nationals carry a 10-year §2 ErbStG shadow; Dutch nationals carry a 10-year erfbelasting shadow; US citizens face permanent worldwide US estate tax. UAE’s nil-tax status provides zero relief against these home-country charges because there is no UAE death tax to credit against them. Additionally, non-Muslim expatriates in UAE need a registered DIFC Will (Dubai) or ADGM Will (Abu Dhabi) to ensure assets pass according to their wishes rather than UAE civil court default rules.

French succession tax can apply through three independent mechanisms: (1) if the deceased was a French fiscal domiciliary — worldwide assets at rates up to 45% for direct family; (2) if any heir has been French-resident for 6 of the prior 10 years — all worldwide assets received; (3) for French-situs assets — always, regardless of the deceased’s domicile or nationality. A UK national living in London who dies and leaves an estate to a child who has lived in Paris for 8 years triggers French succession tax on the entire worldwide inheritance received by that child — even though neither the deceased nor the assets have any French connection.

No — Australia has no federal or state inheritance tax. However, capital gains tax on deemed disposal at death applies when assets pass to foreign-resident beneficiaries. When an Australian tax resident dies with assets passing to a beneficiary who is not an Australian tax resident, CGT is assessed on the deceased’s final return at market value on the date of death — not deferred to the eventual sale of the asset. The main residence exemption is unavailable when the beneficiary is a foreign resident. Australian superannuation passes outside the estate but death benefits to non-dependant beneficiaries are taxed at up to 17%.

Forced heirship is a legal rule in civil law countries that reserves a fixed portion of the estate for certain heirs regardless of what the will says. It applies in France (up to 75% reserved), Spain (67% mainland), Italy (50–75%), Portugal (50–67%), Germany (Pflichtteil — half of intestate share in cash, enforceable against any estate), Netherlands, Belgium, Japan, Brazil (50%), Chile (75% — the most restrictive in Latin America), and many others. Real estate in any of these countries always follows local forced heirship rules regardless of the deceased’s nationality, domicile, or will. The EU Succession Regulation art.22 election removes forced heirship for movable assets in EU countries — but never for real estate.

Not necessarily separate wills, but coordinated succession planning that covers all countries. For EU assets, an EU Succession Regulation art.22 election of your nationality’s succession law in a single will can govern your entire EU succession for movable assets. For assets in the UAE, a DIFC Will (Dubai) or ADGM Will (Abu Dhabi) is strongly recommended for non-Muslim expatriates. For assets in Indonesia, Philippines, Saudi Arabia, and Kuwait, local succession processes are mandatory regardless of any foreign will. Having multiple coordinated wills that do not contradict each other — prepared by advisers in each relevant jurisdiction who have actually communicated with each other — is the minimum adequate structure.

Estate tax is charged on the deceased’s estate before distribution — the executor pays from estate assets. UK IHT and US estate tax work this way. Inheritance tax is charged on each individual heir’s received share — each beneficiary pays separately based on what they receive and their relationship to the deceased. France, Germany, Japan, Belgium, and the Netherlands all use inheritance tax. When an estate-tax country and an inheritance-tax country both claim the same assets, two different people owe two different taxes. Treaty credits often fail to bridge this because credits typically require the same taxpayer to have paid in both countries — but the estate paid the estate tax, not the heir.