James Mackenzie
Solicitor, Private Client

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Foreign and cross border issues

Key Contact

James Mackenzie
Solicitor, Private Client

james.mackenzie@asb-law.com

Foreign and cross border issues

If you have close connections with another country – maybe family or property overseas – you are not alone. It is increasingly common for people to have assets in more than one country, and to spend time living and working abroad.

It will come as no surprise to you that no two country’s laws are the same, which means that careful planning is crucial. 

In common law countries (where the law is developed through the decisions of the courts) such as England, you can generally leave your property to whomever you wish. Contrast this with the position in civil law countries (where the law is codified by statute) like France: the freedom to dispose of your property is more limited.

It might seem natural to assume that should you choose to retire abroad your estate would no longer be subject to the UK tax regime. This isn’t the case, and your executors and beneficiaries may find that your estate is still subject to inheritance/income tax in this country.

Our experienced team can offer practical advice tailored to your particular circumstances.

To discuss or review your own situation, please contact James Mackenzie.