TL;DR
- From 6 April 2025, the UK moved from domicile-based to residency-based inheritance tax rules, a major shift for expatriates and long-term residents (GOV.UK).
- Switzerland cut compulsory heirship shares in 2023 and, from January 2025, lets foreign residents choose their national law and jurisdiction for succession planning (Mondaq; Altenburger).
- Spain’s regions increasingly grant near-100% inheritance tax relief to close relatives (e.g., spouses and children), sharply reducing the effective burden in 2025 (Blacktower).
- Eight EU countries levy no inheritance tax at all, underscoring how location can dramatically change outcomes for heirs (Euronews).
- Global momentum continues: South Korea plans a beneficiary-based system by around 2028, signaling wider reform trends (Reuters).
Last updated 29 October 2025
Where you live when you pass away can determine how much of your legacy your heirs actually receive. For globally mobile families, recent reforms mean the “right” country can translate into lower inheritance taxes, more control over who inherits, and fewer cross-border headaches.
This guide highlights current hotspots and reforms expats should watch—so you can align residency, assets, and succession plans for maximum certainty and minimal tax leakage.
Table of contents
- Understanding inheritance and estate taxes
- UK: Inheritance Tax Reform for Expatriates (2025)
- Switzerland: More freedom over your estate (2023–2025)
- Spain: Regional inheritance-tax relief for families (2025)
- Zero-inheritance-tax and low-tax jurisdictions: what to know
- International reform trends
- Choosing a base: practical residency and structuring tips
- Quick comparison: who benefits where?
- FAQs
- Conclusion
Understanding inheritance and estate taxes
Two concepts are often conflated:
- Estate tax is charged on the estate itself before assets are distributed.
- Inheritance tax is charged to the beneficiary after they inherit.
Rates, exemptions, and legal rules differ widely between countries—and sometimes within them. In the EU alone, there are significant disparities; notably, eight EU countries do not levy inheritance tax, while others apply high top rates, reinforcing the importance of jurisdictional planning (Euronews).
UK: Inheritance Tax Reform for Expatriates (2025)
On 6 April 2025, the UK switched its inheritance tax (IHT) system from a domicile-based approach to residency-based rules. In broad terms, the reform ties IHT exposure more closely to an individual’s UK residence history, rather than the historically complex and contentious concept of domicile (GOV.UK).
- Why it matters for expats: Many British expats who have lived overseas for a decade or more will no longer face UK IHT on their foreign assets, while non-UK assets of long-term UK residents remain within scope for a limited period after leaving the UK (GOV.UK).
- Nil-rate band still matters: The UK’s basic IHT threshold remains £325,000 for singles, with the freeze extended to 2030—making careful relief planning (e.g., residence nil-rate band, spousal transfers) as relevant as ever (Reuters).
- Trusts and non-dom legacy structures: The reform interacts with changes to the UK’s non-dom regime and the IHT treatment of trusts, requiring careful review for families with historic offshore arrangements (Deloitte).
Action point: If you are a UK national or long-term UK resident with assets abroad, revisit your will, trust structures, and residence footprint to align with the new rules (GOV.UK).
Switzerland: More freedom over your estate (2023–2025)
Switzerland delivered a two-step boost to expat estate planning:
- January 2023 (domestic succession law): Switzerland reduced forced heirship portions, expanding testamentary freedom. For example, children’s compulsory share was cut (from 3/4 to 1/2 of their statutory entitlement), increasing the freely disposable portion of the estate (Mondaq).
- January 2025 (private international law): New rules give foreign-resident decedents clearer options to choose their national law to govern succession and to streamline jurisdiction in cross-border estates—making planning more predictable for expats with multi-country ties (Altenburger).
Action point: Foreign residents in Switzerland should formalize a will that elects their home-country law where appropriate, coordinating with asset location and family objectives (Altenburger).
Spain: Regional inheritance-tax relief for families (2025)
Spain’s national inheritance and gift tax framework allows substantial regional variation. In 2025, several key regions (e.g., Andalusia, Madrid, the Balearics) provide near-100% relief for close relatives such as spouses and children, significantly reducing tax on family transfers (Blacktower).
- Why it matters: Expats who plan residency and hold assets in regions offering generous relief can pass property to immediate family at negligible cost in many cases (Blacktower).
- But beware fragmentation: The rules differ by autonomous community; reliefs, thresholds, and documentation can vary, so location selection inside Spain is critical (Blacktower).
Action point: If Spain is your base, choose your region strategically and keep your will and asset titling aligned with the regional regime that applies to you (Blacktower).
Zero-inheritance-tax and low-tax jurisdictions: what to know
Within Europe, there is a clear divide: eight EU countries have no inheritance tax, while others levy high rates or limit reliefs, reinforcing how much the choice of country (and even region) can alter outcomes (Euronews). Outside the EU, some jurisdictions also operate without an inheritance tax. Regardless of where you settle, three practical points apply:
- Residency footprint rules can create ongoing tax exposure even after leaving (e.g., tail rules), as seen in the UK’s new residence-based approach (GOV.UK).
- Choice-of-law tools can let you bypass local forced heirship (e.g., Switzerland 2025), but only if correctly elected in a valid will (Altenburger).
- Internal disparities (e.g., Spain’s regional reliefs) mean asset location inside a country can be as important as the country itself (Blacktower).
Coordinate your residence, will, and asset location with tax and succession rules for a robust cross-border plan. For help structuring residence status, see our guidance on residency permits and citizenship, and align your plan with local tax and investment considerations.
International reform trends
Reform momentum is building beyond Europe. South Korea, traditionally among the world’s highest IHT jurisdictions, has proposed shifting from an estate-based to a beneficiary-based inheritance tax by around 2028, aiming to reduce burdens and simplify transfers across generations. This aligns with broader policy discussions in OECD countries about the efficiency and fairness of inheritance taxation (Reuters).
For expats, this underscores a key point: rules are changing fast. Building flexibility into your plan—via review clauses, multi-jurisdictional wills, and portable holding structures—can future-proof your strategy.
Choosing a base: practical residency and structuring tips
Before you move (or before you buy assets in a new country), map your estate plan to the local tax and succession regime:
- Clarify exposure triggers: Confirm what connects you to IHT or succession law (residency years, domicile concepts, situs of assets, tail rules) in your target jurisdiction (GOV.UK).
- Use choice-of-law where available: If permitted, elect your national law in a will to avoid forced-heirship friction (e.g., Switzerland from 2025) (Altenburger).
- Pick your region wisely: In countries with regional variation (e.g., Spain), choose where you reside and hold real estate with the relief landscape in mind (Blacktower).
- Integrate residency and citizenship strategy: The right residence permit can unlock local planning tools and tax status. Explore options in our residency and citizenship guides.
- Coordinate with asset structuring: Align your holding vehicles and beneficiary designations with the laws that will apply. Cross-check with your home country rules and treaties, where relevant.
Quick comparison: who benefits where?
| Jurisdiction | What changed (year) | Key expat impact | Who may benefit most |
|---|---|---|---|
| United Kingdom | Shift to residency-based IHT (2025) | Overseas assets of long-term non-residents can fall outside UK IHT; tail rules apply for a limited period after leaving | UK nationals living abroad long-term; mobile executives planning exit timing (GOV.UK) |
| Switzerland | Reduced forced heirship (2023); choice-of-law/jurisdiction (2025) | More freedom to direct assets; foreign residents can elect their national law for succession | Foreign residents with cross-border estates and blended families (Mondaq; Altenburger) |
| Spain | Regional reliefs expanded (2024–2025) | Near-100% relief for close relatives in several regions | Families planning to pass Spanish homes/businesses to spouses/children (Blacktower) |
FAQs
How did UK inheritance tax change in April 2025?
The UK replaced its domicile-based approach with residency-based rules. Broadly, worldwide assets are linked to long-term UK residence, with a limited “tail” after departure; many expats living abroad for a decade or more will no longer face UK IHT on foreign assets. Review the details and examples on the official guidance (GOV.UK).
What did Switzerland change for expats’ succession planning?
Two key reforms: in 2023, compulsory heirship shares were reduced, expanding freedom in wills; in 2025, private international law changes allow foreign residents to choose their national law and clarify jurisdiction for cross-border estates (Mondaq; Altenburger).
Is inheritance tax low or zero in parts of Spain?
Yes—several autonomous regions, including Andalusia, Madrid and the Balearics, offer near-100% relief for inheritances to close relatives such as spouses and children. Rules and reliefs vary by region, so planning where you live and hold assets is essential (Blacktower).
How many EU countries have no inheritance tax?
Eight EU countries have no inheritance tax, illustrating the diversity of approaches across the bloc (Euronews).
What’s changing in South Korea’s inheritance tax?
South Korea has proposed shifting to a beneficiary-based inheritance tax with implementation targeted around 2028, indicating a broader international trend to lighten inheritance tax burdens (Reuters).
Conclusion
For expats seeking favorable inheritance and estate planning, the most attractive destinations today are those that combine predictable rules with meaningful tax reliefs. The UK’s shift to residence-based IHT, Switzerland’s expanded testamentary freedom and choice-of-law tools, and Spain’s regional reliefs for close family demonstrate how the right base can materially improve what your heirs keep (GOV.UK; Mondaq; Altenburger; Blacktower). Build flexibility into your plan, align residence and asset location, and formalize your will with the right choice-of-law where available.
Need a cross-border roadmap tailored to your family? Contact our private client team to coordinate residency, visas, residency, citizenship, and tax-efficient structures across jurisdictions. Get in touch.
