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How We Can Help With International Estate Planning
To ensure assets are protected and managed seamlessly across borders, expert guidance is required when navigating the complexities of international estate planning.
At Myerson Solicitors, we specialise in providing tailored international trusts and Wills services for UK citizens with assets abroad, as well as for international clients seeking to establish a trust in the UK.
With extensive experience in cross-border estate planning, our team works closely with an established network of international lawyers, accountants, and tax advisers to address the unique legal, tax, and regulatory challenges that come with holding assets across multiple jurisdictions.
We can help with a range of specific personal and family situations, including:
- UK citizens owning property or investments overseas – ensuring international assets are structured and managed tax-efficiently.
- Individuals planning to retire abroad – assisting with the creation of Wills and trusts that cover assets in multiple countries, avoiding conflicts in inheritance laws.
- Non-UK residents establishing UK-based trusts – creating a secure, compliant trust structure in the UK to protect assets or benefit UK-based family members.
- Expatriates with assets in the UK – addressing estate planning needs that align with UK and foreign tax laws for individuals residing outside the UK.
- Families with dual or multiple citizenships – managing complex inheritance and tax obligations across multiple countries.
- International business owners – protecting personal and business assets held in different jurisdictions with strategies tailored to cross-border requirements.
- Parents and grandparents providing for beneficiaries abroad – creating trusts and Wills that support overseas beneficiaries while maintaining compliance with UK regulations.
- High-net-worth individuals – addressing the specific needs of those with diverse international portfolios, including real estate, investments, and business interests.
International Trusts: Onshore and Offshore Options
Trusts are an essential component of estate planning and are widely used for a variety of purposes, including asset protection, succession planning, and tax efficiency.
Whether set up domestically (onshore) or in another country (offshore), international trusts provide flexibility and control over asset distribution, enabling individuals to secure and manage wealth across borders effectively.
Choosing between an onshore or offshore trust depends on individual circumstances, goals, and the complexity of one’s assets.
Onshore trusts are established under the legal system of the person who sets up the trust (Settlor's) home country.
Offshore trusts are set up under the jurisdiction of a foreign country. Many settlers in the United Kingdom like to set up trusts in jurisdictions such as Jersey, Guernsey, Isle of Man, Bermuda, Monaco and others.
How We Can Help with International Trusts
Whether you’re a UK citizen with assets abroad or live in another jurisdiction and want to set up a Trust in the UK we can work with our network of lawyers, accountants and tax advisers to create a personalised trust solution to help you establish and manage your onshore or offshore trust.
Alongside our network we can support with:
- Navigating Complex Tax Implications - We work closely with you to evaluate tax advantages in various jurisdictions, ensuring compliance with UK tax laws while helping you maximise potential tax efficiencies. For offshore trusts, we partner with international tax advisers to create strategies that align with both UK regulations and local tax rules, managing liabilities to avoid unexpected costs.
- Ensuring Optimal Legal Protection Across Jurisdictions - Our international experience enables us to help you choose the right jurisdiction for asset protection. We assess and explain the varying levels of legal security available across different offshore jurisdictions, ensuring your trust is set up in a country with the optimal level of asset protection to suit your needs. We handle all legal requirements, working to structure the trust in a way that minimises exposure to potential claims, while safeguarding assets from risks in line with your goals.
- Addressing Privacy Concerns in Wealth Management - Myerson recognises the importance of confidentiality in wealth management. Our team advises on jurisdictions known for strict privacy laws, enabling you to establish a trust that maintains the highest levels of confidentiality. We navigate regulatory requirements carefully to protect your personal information while ensuring compliance with international reporting standards, balancing your desire for privacy with necessary transparency.
- Managing the Costs and Complexities of Offshore Trusts - Offshore trusts often involve more intricate compliance and administration. We offer end-to-end support, handling the initial setup, ongoing administration, and regulatory compliance required to maintain your trust. We guide you through practical aspects, such as currency exchange and international banking, and coordinate with our network of accountants and financial institutions to streamline costs. Our aim is to help you weigh the costs against potential benefits, ensuring your trust is structured efficiently and sustainably.
International Wills
For UK citizens living abroad who hold assets in the UK, establishing a UK will is essential for ensuring that those assets are managed and distributed according to their wishes.
Without a UK will, UK assets could be subject to local inheritance laws, which may not align with an individual’s preferences, especially in cases where multiple jurisdictions are involved.
A UK will can simplify the estate administration process, reducing potential delays and complications, and providing peace of mind.
At Myerson Solicitors, we specialise in drafting international wills tailored for expats and cross-border estates, helping to ensure that your UK assets are safeguarded and effectively passed on to your intended beneficiaries.
International Estate Planning FAQs
Can international estate planning reduce my inheritance tax?
Inheritance Tax is often governed by the concept of “domicile” rather than “residence”.
Whilst residence can be a factor in determining domicile, it is not the main factor and looking at all aspects of an individual’s life leading to death will be important, such as where a person was born, educated, chooses to set up their home and raise a family, where they are employed, down to where a person intends to die.
Once domicile is established, the starting point is that the deceased will be subject to Inheritance Tax in that country, but it will depend on what other assets the deceased has and where those assets are, as there may be tax in the country where the assets are based and double taxation treaties may apply.
How often should an international estate plan be reviewed?
Like a domestic Will, international estate planning should be reviewed on any changes of circumstances to include acquiring more assets in different locations, changing employment to a different country, getting married and setting up home elsewhere. Changes in asset values also make a difference to planning as different taxation thresholds may apply.
Can a single will cover assets in multiple countries?
A single Will can cover assets in multiple countries but is not necessarily the most beneficial way of dealing with things as it could mean a conflict in law (e.g. French law does not recognise Trusts) or a delay in administering an estate due to having to extract a grant (link to existing blog/estate page) in the home country and potentially having to wait until it has been granted before having the foreign court resealing. Whether separate Wills are required depends on each individual’s circumstances.
Our International Probate Services
Our international probate solicitors can advise on the concept of domicile, which is complicated and goes beyond where someone lives and works. In some cases, where there is more than one Will, we can advise on which Will covers what assets.
Obtaining and resealing grants of representation:
Our international probate solicitors can obtain a UK grant of representation where required.
If a grant has been acquired in a commonwealth jurisdiction already, but there are UK assets, then we can reseal an existing foreign grant in the UK.
Assets held abroad:
Each jurisdiction has its own rules for dealing with assets. Some jurisdictions have different succession laws, which can override what is in a person’s Will. It is, therefore, important to obtain expert advice in that jurisdiction for any foreign assets in an international estate.
Our international probate solicitors often work with experts in different jurisdictions. We have contacts with foreign lawyers worldwide through MSI Global Alliance and STEP (Society of Trusts and Estates Practitioners) who can assist.
If you appoint us in your international probate matter, our dedicated team will be your point of contact to coordinate the entire process.
Our international probate lawyers can manage the estate administration, liaising with other professionals where necessary, and we will keep you updated on the progress of your matter.
We can also organise the notarising and translating documents so that matters documents can be used abroad.
Advising on domicile and dealing with estates for non-domiciles:
Domicile is important when dealing with international estates, and it will change the nature of our advice.
Where the Deceased was domiciled abroad, even if the assets in the UK are modest if a grant is required, the full Inheritance Tax return must be completed, including the supplemental pages relating to foreign domicile.
Our international probate solicitors understand the information that HMRC seeks in these international estate cases, and we can put together the claim for foreign domicile for the family.
The tax position is different depending on the domicile status of the Deceased. We can advise on the inheritance rules that apply to your foreign assets based on the specific circumstances.
Why Work With Our International Estate Planning Team
Our team has extensive experience working with clients who hold assets across multiple jurisdictions, ensuring expert handling of complex international matters.
Through our strong connections with prestigious networks such as STEP and MSI Global, we collaborate with trusted lawyers, accountants, and other specialists worldwide.
This allows us to provide a coordinated, joined-up service, delivering tailored solutions that address every aspect of your situation with precision and efficiency.
International Estate Planning Case Studies
Tax Planning and Asset Protection for a £50M Business and International Family
Assisting a couple with young children and a thriving business worth around £50 million to look at maximising tax reliefs both during their lifetimes and on death.
One of the couple is domiciled in England and the other has a domicile of origin in the Far East.
We are looking at taxation in different jurisdictions in conjunction with an international tax advisor and elements to be changed to benefit from better income tax rates during their lifetime and then asset protection on death.
Independent Administration of Disputed English Estate with Spanish Property Sale
Acting as independent administrator in a disputed English estate with a co-owned property in Spain.
Instructing Spanish lawyers in the valuation and sale of the property which involves redeeming an existing mortgage.
Estate Planning for French Property with Trusts and Succession Advice
Advising a couple on their Wills and estate planning to include a property held in a company in France.
Liaising with French lawyers to ensure that succession and Inheritance Tax rules are not conflicted and implementing trusts for further asset protection.
Assisting with English Grant for £1.3M Property of Hong Kong Domiciled Deceased
Assisting a lawyer in Australia with the extraction of an English Grant to deal with an English property valued at £1.3 million.
The deceased was domiciled in Hong Kong.
Family Office Advisory: Wills, Trusts, Business, and Repatriating Isle of Man Trust
Advising a client in a Family Office capacity with their Wills, Trusts, business and pensions and bringing an Isle of Mann trust back to England.
Meet Our International Estate Planning Specialists
Contact Our Experts
You can contact our lawyers below if you have any more questions or want more information:
0161 941 4000
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