Yes — this is common and widely underestimated. Multiple countries can simultaneously claim the right to tax the same estate through three independent mechanisms: where the deceased was domiciled (triggers worldwide scope), where the assets are located (triggers situs-state tax), and where the heirs live (triggers heir-side inheritance tax in France, Germany, Netherlands, Belgium, and other countries). There is no European-wide mechanism that prevents this. Relief between countries depends on bilateral tax treaties — which exist for only a minority of European country pairs.

Yes — for up to 10 years after leaving the UK. From April 2025, the UK replaced domicile-based IHT with the Long-Term Resident (LTR) test. Anyone with 10+ qualifying UK tax years carries a departure tail of 3–10 years after leaving (depending on total years of UK residence). During this period, UK IHT applies to worldwide assets including Spanish property, French bank accounts, and Portuguese investments. A UK national who moved to the Costa del Sol in 2021 with 20 years of prior UK residence may remain within UK IHT scope until 2031.

Yes — Spanish Imposto sobre Sucesiones y Donaciones (ISD) applies to Spanish-situs assets regardless of nationality. Rates vary dramatically by autonomous community: Madrid applies near-zero rates for direct family; Andalusia (Costa del Sol) significantly reduced rates; Catalonia higher rates. Post-Brexit, UK nationals assessed as non-resident for ISD purposes may be taxed at Spanish state rates rather than the lower autonomous community rates. No UK/Spain bilateral estate tax treaty exists — all relief is via unilateral credit only.

French succession tax can apply in three independent ways: (1) if the deceased was a French fiscal domiciliary — worldwide assets; (2) if any heir has been French-resident for 6 of the prior 10 years — worldwide assets received; (3) for French-situs assets — always, regardless of where the deceased or heirs are domiciled. Rates reach 45% for direct family and 60% for unrelated beneficiaries. A UK parent who dies in Australia, leaving 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.

Portugal abolished inheritance tax in 2004. Direct-line heirs (spouse, children, grandchildren, parents, grandparents) have been exempt from Imposto do Selo (Stamp Duty) on inherited assets since 2009. Non-direct-line heirs — siblings, cousins, and unrelated beneficiaries — face 10% Imposto do Selo on Portuguese-situs assets. Portuguese real estate always follows Portuguese succession law under lex situs, including forced heirship (quota indisponível). No UK/Portugal or France/Portugal bilateral estate tax treaty exists.

Yes — for 10 full years after leaving Germany. German nationals who emigrate retain unlimited German ErbStG (inheritance tax) exposure on their worldwide estate under §2 ErbStG. This applies regardless of where they now live — UAE, Spain, Switzerland, Singapore. There is no threshold and no partial exemption. Additionally, German-resident heirs independently face German ErbStG on worldwide assets they receive, regardless of where the deceased lived. Moving to a nil-tax jurisdiction provides zero relief against the German shadow.

Yes — independently of any UK tax position. Under French art.750 ter §2, if your children have been French-resident for 6 of the prior 10 years, French succession tax applies to all worldwide assets they receive as heirs — including their share of your UK estate. This applies regardless of where you (the deceased) were domiciled, where your assets are located, and what UK IHT has already been paid by the estate. The UK estate pays UK IHT; your French-resident children additionally owe French succession tax on their received share.

Italian succession tax applies to Italian-situs assets of all deceased, including foreign nationals. Rates: 4% above €1 million per beneficiary for direct relatives; 6% above €100k for siblings; 8% with no exemption for others. Italy also has the azione di riduzione — a 10-year retroactive mechanism allowing Italian forced heirs to challenge lifetime gifts that impaired their quota legittima. This applies to Italian-situs assets regardless of where the deceased was domiciled. No UK/Italy, France/Italy, or Germany/Italy bilateral estate tax treaty exists for immovable property.

Yes — Dutch erfbelasting (inheritance tax) at 10–20% for spouses and children; 18–36% for grandchildren; 30–40% for others. Dutch nationals who emigrate carry 10-year worldwide erfbelasting exposure. Dutch-resident heirs face erfbelasting on worldwide assets received regardless of where the deceased was domiciled. A Dutch/Netherlands bilateral DTA exists with Belgium; partial treaties with France and a few others. Most corridors: unilateral credit only.

Not necessarily — but it is strongly recommended to have a coordinated will (or coordinated wills) that covers all European assets. The EU Succession Regulation (650/2012) allows EU nationals and UK nationals post-Brexit to elect the succession law of their nationality in a single will, which then governs their entire EU succession (movables). This art.22 election must be explicit in the will — it is not automatic. Critical limitation: real estate always follows the law of the country where it is located (lex situs), regardless of any election. Spanish real estate follows Spanish succession law; French real estate follows French law.

The EU Succession Regulation (650/2012) is an EU law that determines which country’s succession law governs a cross-border EU estate, and allows EU nationals to elect their nationality’s succession law. UK nationals can still make a nationality law election under the Regulation in their will — this was confirmed by EU legal interpretation post-Brexit. The election removes the host EU country’s forced heirship for movable assets (bank accounts, shares) but not for real estate (lex situs always applies). The Regulation itself does not govern tax — French succession tax applies regardless of which succession law was elected.

Yes — Greek inheritance tax applies to all Greek-situs assets regardless of the nationality or domicile of the deceased. Category A (direct family — spouse, children, parents): €150,000 exempt per heir, then 1–10%. Category B (siblings and extended family): €30,000 exempt, 5–20%. Category C (others): €6,000 exempt, 20–40%. New Law 5303/2026 introduced reforms to Greek forced heirship rules. All heirs must obtain a Greek AFM (tax identification number) before accepting inheritance. Non-resident heirs have a one-year deadline to renounce if they choose not to inherit.

Yes — Belgium has regional inheritance tax administered by three separate systems: Flemish erfbelasting (Flanders), and droits de succession (Brussels Capital Region and Wallonia). Direct family rates range from 3% to 27–30% depending on region and estate size. Non-direct-family rates reach 65–80%. Belgian-resident heirs face erfbelasting/droits de succession on worldwide assets received. No single Belgium/UK or Belgium/France bilateral estate tax treaty covers all assets — partial instruments exist.

No federal inheritance tax exists in Switzerland. Cantonal inheritance taxes vary significantly: Zurich, Zug, and Schwyz impose zero inheritance tax on direct family; Geneva and Vaud charge higher rates. The applicable canton is where the deceased was domiciled at death. Germany/Switzerland and France/Switzerland bilateral DTAs on inheritances exist — providing structured relief for those specific corridors. Switzerland is a genuinely low-exposure jurisdiction for direct family in most cantons.

Forced heirship is a legal rule 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 for children), Spain (67% mainland — varies by region), Italy (50–75% depending on family structure), Portugal (50–67%), Germany (Pflichtteil — half of intestate share in cash), Netherlands (50% of intestate share), Belgium (50% for children as a group), and Greece (50%). Real estate in each of these countries always follows local forced heirship rules under lex situs, regardless of the deceased’s nationality or domicile.