International Estate Planning for UK Domiciled, Non Domiciles and Expatriates

Cross-border estates are among the most complex and most commonly mishandled areas of estate planning. Whether you are a UK national living overseas, a foreign national with UK assets, or a non-domiciled individual navigating the UK’s inheritance tax rules, getting your estate planning wrong can result in unexpected tax liabilities, costly legal disputes, and assets passing to unintended beneficiaries under foreign law. I have extensive experience advising international clients on UK-focused estate planning – ensuring their affairs are structured correctly on both sides of any border.

UK Domicile and Non-Domicile Planning

UK Domiciled Individuals

If you are UK domiciled, UK inheritance tax applies to your worldwide assets – including property, investments, and bank accounts held anywhere in the world. It is essential that your estate plan accounts for all assets, including those held overseas, and that potential double-taxation exposures are identified and mitigated through available treaty reliefs.

Non-Domiciled Individuals

If you are non-domiciled in the UK, inheritance tax generally applies only to UK-sited assets. However, significant changes to the UK’s non-dom tax regime have begun to take effect from April 2025. New rules are phasing in changes to IHT treatment for long-term UK residents. I stay fully current with these changes and ensure non-dom clients receive accurate, up-to-date advice.

Deemed Domicile

Individuals who have been UK resident for 15 of the preceding 20 tax years may be treated as ‘deemed domicile’ for inheritance tax purposes – meaning their worldwide assets become subject to UK IHT. Careful planning ahead of reaching deemed domicile status can significantly reduce exposure.

Increasingly, families have connections across multiple jurisdictions. I advise on UK-side planning that takes account of international complexity — including EU Succession Regulation (Brussels IV) implications for UK nationals with European property, planning for French and Spanish forced heirship rules in conjunction with UK trusts, coordinating UK wills with local wills in other jurisdictions, and double tax treaty reliefs to prevent the same assets being taxed twice.