Key aspects of multijurisdictional inheritance matters

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Families are rarely confined to one country, and neither are their estates.

When a person passes away, their death can trigger legal consequences across multiple countries, each with its own rules on jurisdiction, applicable law, and taxation.

Three main challenges often arise:

• Jurisdiction: where should the succession take place when the deceased, his assets and heirs are spread across borders?

• Conflict of laws: which legal system governs the estate: the law of the last domicile, of nationality, or of the place where the assets are located?

• Taxation: how can families avoid double (or even triple) taxation, given that few countries have treaties covering inheritance tax?

The answer lies in careful and early planning. Mapping all relevant jurisdictions, engaging local experts, and using tools such as trusts, private foundations, or life insurance can help reduce costs and risks while preserving family wealth across generations.