Emigration changes an individual's income tax and residence position far more quickly than it changes their inheritance tax position. For many long-term expatriates, the estate remains within the scope of UK inheritance tax, and UK-situated assets remain in scope regardless of where the owner lives.
The three questions worth asking early in any expatriate conversation are these: does the client still hold UK-situated assets, does their long-term UK connection still bring the wider estate into scope, and which other jurisdiction also has a claim on the same estate. A yes to either of the first two means UK inheritance tax remains the family's problem.
[Post-2025 long-term residence rules and their interaction with the previous domicile-based tests to be summarised once final HMRC guidance is confirmed. No jurisdiction-specific conclusions should be drawn from this article.]
Cross-border cases also raise practical issues that rarely appear in UK-only planning: double tax treaty relief where it exists, currency exposure between the investment and the eventual liability, the willingness of a provider to accept subscriptions from a given jurisdiction, and the ability of executors in one country to administer assets held in another.
This is the point at which specialist propositions differ markedly from one another. Some are only available to UK residents. Others accept subscriptions from a defined list of approved jurisdictions and can support executors across time zones. Availability should be established before a proposition is discussed with a client, not after.
New Walk works alongside advisers and professional intermediaries acting for internationally based clients. We do not provide tax or legal advice, and cross-border planning should always involve appropriately qualified advisers in each relevant jurisdiction.