The core challenge is straightforward to describe but difficult to solve: different countries have different rules about how wealth is transferred between generations, and those rules do not always agree with each other. A will drafted under English law may not be recognised in Italy. A trust or holding structure established in one jurisdiction may create unintended tax consequences for beneficiaries resident in another. A family business structured across multiple jurisdictions may face conflicting claims from different legal systems.
The Hidden Risks of Doing Nothing
Many families with cross-border exposure operate without a coordinated succession plan. The reasons are understandable: the topic is sensitive, the legal landscape is complex, and the costs of professional advice across multiple jurisdictions can be significant. So the conversation gets postponed.
The problem is that in the absence of a deliberate plan, default rules apply, and those default rules are rarely what the family intended. In many European jurisdictions, forced heirship provisions dictate how a certain percentage of the estate must be distributed, regardless of what a will says. In the UK, by contrast, testamentary freedom gives the individual more control, but only if the right instruments are in place. When assets sit across both systems, the result of poor cross-border estate planning can be legal conflict, frozen accounts, and years of dispute.
There is also a tax dimension. Inheritance planning for international families must account for the possibility of tax obligations arising in more than one jurisdiction simultaneously. Double taxation treaties exist for some country pairs, but they are not comprehensive, and navigating them requires specialist knowledge that most generalist advisors do not have.
Building a Cross-Border Succession Framework
Effective multi-generational wealth transfer planning for international families requires three things working together. First, a clear map of all assets, entities, and jurisdictions involved. This sounds basic, but many families do not have a single document that shows the full picture: because no single advisor has ever been asked to create one.
Second, alignment between the legal instruments in each jurisdiction. This may involve separate wills for assets in different countries, carefully drafted to avoid conflict. It may require the use of trusts, foundations, or holding structures, but only where these genuinely serve the family’s objectives and are compliant with the rules in every relevant jurisdiction.
Third, a governance framework that involves the next generation. The most well-structured plan in the world will fail if the people who inherit the wealth are not prepared to manage it. This means conversations about values, responsibilities, and expectations: ideally facilitated by someone who understands both the family dynamics and the technical complexity.
Starting the Conversation
The best time to plan a cross-border succession is before it becomes urgent. Ideally, the framework is put in place while the family patriarch or matriarch is actively engaged and able to make informed decisions about how wealth should be distributed, who should manage it, and what structures are needed to protect it.
At Konfido, we provide the coordination layer for families with interests across Italy, the UK, Switzerland, and the broader European and Middle Eastern markets. Our role is to connect the local specialists, legal, tax, and financial, into a single coherent strategy, and to give the family a clear, consolidated view of how their wealth is structured and protected across jurisdictions. The planning belongs to the family. The coordination belongs to us.