Estate and succession planning considerations for cross-border assets

Cross-border assets introduce legal, tax, and practical complexities that can affect how wealth transfers across generations. Effective estate and succession planning for international holdings requires understanding multiple jurisdictions, currency exposures, applicable regulations, and the interaction of wills, trusts, and local inheritance rules. This article outlines key considerations to help structure a resilient plan.

Estate and succession planning considerations for cross-border assets

International holdings need clear, well-documented plans to reduce uncertainty for heirs and beneficiaries. When assets sit in more than one jurisdiction, a single approach rarely fits all: wills, trusts, retirement accounts, and investment portfolios can be subject to different taxation regimes and legal rules. Addressing these complexities early—while considering regulation, compliance, and practical transfer mechanisms—reduces the likelihood of disputes and unexpected tax or administrative burdens.

How does taxation affect cross-border estates?

Taxation is one of the most immediate considerations for cross-border estate planning. Different countries apply inheritance tax, estate tax, or succession duties in varying ways, and some taxes can be triggered by domicile, residency, or the location of the asset itself. Coordinating tax treatment across jurisdictions often requires specialized tax advice to avoid double taxation, to evaluate available treaties, and to determine whether investing through certain entities or jurisdictions can create efficiencies without contravening local rules. Estate tax exposure can materially change the amount that beneficiaries receive, so clear modeling and timely compliance are essential.

What compliance issues arise for cross-border assets?

Compliance encompasses reporting obligations, anti-money-laundering requirements, and adherence to local fiduciary standards. Financial institutions typically require thorough documentation for crossborder holdings and may report accounts under international information-exchange regimes. Beneficiaries and executors must also respond to formal processes such as obtaining probate or equivalent court orders in multiple jurisdictions. Failure to follow local procedures can delay distributions and increase administrative costs. A proactive compliance checklist that includes up-to-date documentation, powers of attorney, and appointed local representatives can smooth transitions.

How does currency risk influence succession plans?

Currency fluctuations can reduce or amplify the value of foreign assets when measured in a beneficiary’s home currency. For retirees and heirs relying on income from investments, currency volatility can affect purchasing power and retirement planning. Hedging strategies, multi-currency accounts, or distributing assets in the currency of expected expenses can mitigate risk, but each approach carries costs and regulatory implications. Considerations about currency should be integrated with choices around where to hold cash, bonds, or foreign-denominated investments within an estate or trust structure.

How to structure an estate for cross-border holdings?

Choosing between wills, trusts, nominee arrangements, or corporate holding structures depends on personal circumstances, local laws, and the types of assets held. Trusts can offer continuity and privacy for a crossborder portfolio and may simplify the administration of assets across jurisdictions, but trusts are treated differently around the world for tax and legal purposes. Wills should be coordinated with local legal instruments—an internationally valid will or multiple local wills might be appropriate. Professional advice on regulation, fiduciary duties, and the interaction between domestic and foreign succession laws is crucial to avoid conflicts and unintended outcomes.

How does diversification affect estate risk and investing decisions?

Diversification remains a core investment principle when assets are held internationally, reducing concentration risk across countries, asset classes, and currencies. For estate planning, diversification also affects liquidity: illiquid foreign real estate or business interests can complicate distributions and create tax events for heirs. Balancing long-term investing and wealth preservation with the need for executable, liquid assets for succession (for example to pay taxes or settle claims) helps manage risk. Regular portfolio reviews that consider crossborder regulation, local market access, and retirement goals support robust succession outcomes.


Provider Name Services Offered Key Features/Benefits
UBS Wealth Management International wealth planning, trusts, investment management Global presence, multidisciplinary teams for tax and estate coordination
HSBC Private Banking Cross-border banking, investment advisory, succession planning Large international footprint, multi-currency solutions for retirement and estate needs
BNY Mellon Wealth Management Custody, investment management, fiduciary services Strong custody infrastructure useful for multi-jurisdiction asset administration
Julius Baer Private banking, trust services, portfolio management Tailored wealth structuring with focus on crossborder clients
Société Générale Private Banking Investment advisory, estate planning, lending European regulatory expertise and bespoke solutions for international families

Prices, rates, or cost estimates mentioned in this article are based on the latest available information but may change over time. Independent research is advised before making financial decisions.

How to manage a crossborder portfolio and choose advisors?

Selecting advisors who understand both the jurisdictions involved and the client’s overall objectives is central to effective succession planning. Consider using a team that includes crossborder tax specialists, estate attorneys in relevant countries, licensed fiduciaries, and investment professionals familiar with multi-jurisdiction portfolios. Governance documents—such as lasting powers of attorney, health directives, and clearly drafted beneficiary designations—should be reviewed regularly. Transparent communication with family members and appointed trustees helps ensure intentions are understood and reduces the risk of disputes.

Cross-border estate planning blends legal, tax, investment, and practical operational issues. Addressing taxation, compliance, currency exposure, asset structure, and diversification together, with expert advice tailored to the jurisdictions involved, increases the likelihood that wealth transfers proceed smoothly and in line with the owner’s intentions.