Cross-Border Estate Planning

Your assets don't stop at borders. Neither should your plan.

General guidance for nomads, diaspora families, and international professionals navigating inheritance across jurisdictions. Not legal advice - a starting point for the right conversation.

⚠ Notice All content on HeirPath is general educational information only. It does not constitute legal, tax, or financial advice. Laws vary by jurisdiction and change frequently. Always consult a qualified professional before making decisions.

Five layers of support, from free to specialist

01
Free

Guides & Education

Country-pair articles, concept explainers, and planning checklists for the internationally mobile.

  • Country-pair inheritance overviews
  • Domicile, situs & treaty guides
  • Lifecycle planning checklists
  • Glossary & framework explainers
Browse Guides β†’
03
Free

Planning Tools

Two free tools that map your corridor exposure and compare retirement destinations β€” and show you where a Guided Report takes you further.

  • Corridor Lookup β€” three-trigger regime map
  • Retirement Compare β€” up to 4 destinations
  • Treaty coverage & forced heirship flags
  • Free β€” no sign-up required
Try the Tools β†’
04
Paid

Guided Reports

A structured scenario summary based on your inputs - framed as an educational briefing, not advice.

  • AI-generated scenario report
  • Key risk flags & planning triggers
  • Questions to ask your adviser
  • Downloadable PDF
Get a Report β†’
05
Building

Adviser Registry

A curated directory of lawyers, notaires, and tax accountants who specialise in cross-border estates.

  • Searchable by country-pair specialism
  • Verified professional profiles
  • Direct contact & booking
  • Growing over time
Find an Adviser β†’

Start with your corridor

🏳 ↔ 🏳

Country 1 ↔ Country 2

The complete guide to inheritance tax for expats and internationally mobile families. Covers the UK, France, Germany, UAE, Australia, US citizens abroad, and 14 key corridors. Free Β· No email required.

No Treaty High Exposure
Read Guide β†’
πŸ‡¬πŸ‡§ ↔ πŸ‡¦πŸ‡Ί

United Kingdom ↔ Australia

The UK–Australia corridor is one of the most travelled by British emigrants — yet there is no inheritance tax treaty between the two countries. UK Inheritance Tax follows UK-domiciled individuals wherever they live. Many discover this too late.

No Treaty High Exposure
Read Guide β†’
πŸ‡«πŸ‡· ↔ πŸ‡¦πŸ‡Ί

France ↔ Australia

There is no bilateral inheritance or estate tax treaty between France and Australia. This single fact has significant consequences for diaspora families with connections to both countries — and most are unaware of it until it is too late.

No Treaty High Exposure
Read Guide β†’
πŸ‡¬πŸ‡§ ↔ πŸ‡«πŸ‡·

United Kingdom ↔ France

The UK–France corridor is one of the most common — and most misunderstood — cross-border inheritance situations in Europe. The two systems operate on fundamentally different principles, creating overlaps, gaps, and surprises that catch families unprepared.

Treaty (Limited) High Exposure
Read Guide β†’
πŸ‡«πŸ‡· ↔ πŸ‡ͺπŸ‡Έ

France ↔ Spain

France and Spain share one of Spain’s three inheritance treaties. But the 1963 convention has known gaps β€” including the bank account dispute β€” and Art 750 ter para 3 operates through beneficiary residence regardless of where the treaty allocates taxing rights on the estate itself.

Treaty (Limited) Medium Exposure
Read Guide β†’
πŸ‡«πŸ‡· ↔ πŸ‡΅πŸ‡Ή

France ↔ Portugal

Neither France nor Portugal levies inheritance tax in the way most people fear. But the Art 750 ter beneficiary trap, the absence of a bilateral treaty, and the interaction of two forced heirship systems create real risks for families straddling these two countries.

No Treaty Medium Exposure
Read Guide β†’

Map your corridor. Compare destinations. Then go deeper.

Two free tools that surface the questions your cross-border situation actually raises. When you need the full written analysis, a Guided Report takes it further.

Corridor Lookup

Map your three-trigger exposure

Select deceased domicile, asset location and heir residence. See which regimes apply, where treaties exist, and where the gaps are β€” for your specific country combination.

Open Corridor Lookup β†’
Retirement Compare

Compare up to 4 destinations

Choose your origin country and up to four retirement destinations. Compare inheritance tax profiles, forced heirship rules, treaty coverage and planning flags side by side.

Open Retirement Compare β†’
Both tools are free. When you need the full written analysis β€” Get a Guided Report β†’

See where your inheritance exposure lies

Enter your situation - residency, assets, family structure - and map your risk zones. Not a tax calculator. A starting point for the right questions.

Open the Simulator β†’

3 free scenarios Β· No account required

Find specialists who understand your situation

βš–οΈ

David Chen

Solicitor β€” Private Client & Estates Β· Hong Kong, Hong Kong

πŸ‡­πŸ‡° Hong Kong ↔ πŸ‡¬πŸ‡§ UK πŸ‡­πŸ‡° Hong Kong ↔ πŸ‡¦πŸ‡Ί Australia πŸ‡­πŸ‡° Hong Kong ↔ πŸ‡ΈπŸ‡¬ Singapore
βš–οΈ

James Thornton

Solicitor β€” Private Client Β· London, United Kingdom

πŸ‡¬πŸ‡§ UK ↔ πŸ‡«πŸ‡· France πŸ‡¬πŸ‡§ UK ↔ πŸ‡¦πŸ‡Ί Australia πŸ‡¬πŸ‡§ UK ↔ πŸ‡­πŸ‡° Hong Kong
βš–οΈ

Sophie Laurent

Notaire Β· Paris, France

πŸ‡«πŸ‡· France ↔ πŸ‡¬πŸ‡§ UK πŸ‡«πŸ‡· France ↔ πŸ‡¦πŸ‡Ί Australia πŸ‡«πŸ‡· France ↔ πŸ‡ΊπŸ‡Έ USA