In April 2025, the United Kingdom stopped asking where a person was domiciled and started counting the years he had lived there. Anyone resident for 10 of the previous 20 tax years now pays inheritance tax at 40% on worldwide assets, and the exposure follows him for up to a decade after he leaves.
Italy moved the other way on price. Wealthy newcomers who move their tax residence there now pay a flat €300,000 a year, up from €200,000, and in exchange their foreign assets pass to heirs free of Italian inheritance tax.
The United States, meanwhile, lets its own citizens leave $15 million tax-free in 2026, while a foreigner holding American shares gets $60,000.
For a family with three passports and homes on two continents, these rules stack. The usual assumption is that the newest citizenship sets the rules. In practice, only a handful of countries tax by nationality at all, and most of them are countries investors are trying to leave.
Three Ways a Country Claims Your Estate
Every inheritance tax system answers one question: what connects this death to us? The answers fall into three groups.
Residence. Most countries tax the worldwide estate of someone who lived there, and some measure that over many years rather than on the day of death. The UK, Italy, Ireland, and France all work this way.
Citizenship. A few countries keep taxing nationals after they leave, either for life, as the United States does, or for a fixed number of years, as Germany, the Netherlands, Japan, and Greece do.
Location of the assets. Nearly every country with the tax charges it on property within its borders, whoever owns it. A Lisbon apartment or a block of US shares can create a bill even when nothing else about the family touches that country.
Some systems also look at the heir. France and Spain can tax a resident heir on an inheritance from a foreigner who never set foot in either country.
Koen Lozie of Aver Associates counts this among the mistakes globally mobile families make most often. “Families plan around the parent and forget the children,” he says. Germany, France, and Spain all tax inheritances based on where the beneficiary lives, so “a parent living a low-tax life in Dubai or Malta can still leave a child in Paris or Munich with a large inheritance tax bill.”
A citizenship by investment (CBI) passport fits into none of these on its own. It changes the bill only when it comes with a real change of residence, or when the old citizenship goes.
The Passport That Follows You Is the Old One
🇺🇸 The United States is the only major economy that taxes its citizens’ estates wherever they live. The 2026 exemption is $15 million per person, with 40% charged above it. A US citizen who adds a Caribbean passport changes nothing about that.
Renouncing changes the bill but does not end it. A “covered expatriate,” broadly someone with $2 million in net worth or an average annual US tax bill above roughly $206,000 at exit, is caught by section 2801. Under final regulations effective January 1, 2025, any US citizen or resident who inherits from him pays 40% on the bequest, and the first Form 708 returns are due July 15, 2027.
The tax moves from the estate to the children. For a family whose heirs stay in America, renunciation can cost more than staying.
🇩🇪 Germany keeps its nationals in the net for five years after they leave, taxing their worldwide estate as if they had never gone. A German who moves to a low-tax country then faces a second five-year period under the Foreign Tax Act, covering German-source assets. If any heir lives in Germany, his share is taxable regardless.
🇳🇱 The Netherlands treats a Dutch national as resident for 10 years after emigrating. Children pay 10% up to €138,641 and 20% above it, on the worldwide estate. Foreigners who leave are released after one year, and only for gifts.
🇯🇵 Japan applies the same 10-year clock. A Japanese national who had an address in Japan within 10 years of death leaves his worldwide estate exposed to rates of up to 55%. Foreigners in Japan on temporary visas are taxed on Japanese assets only.
🇬🇷 Greece taxes property in Greece and also the movable assets abroad of Greek citizens. Those foreign movables are exempt only once the citizen has lived abroad for 10 consecutive years.
None of these countries cares which passport an emigrant acquired next. A Dutch entrepreneur with a Dominican passport is Dutch for inheritance purposes until the clock runs out.
Where Residence Decides
Residence by investment (RBI) holders rarely become tax residents, and that is usually the point. Those who do move face the rules below.
🇬🇧 The UK’s long-term residence test replaced domicile on April 6, 2025. After 10 of the previous 20 tax years, worldwide assets are taxed at 40% above the £325,000 nil-rate band. The tail after departure is three years for someone resident 10 to 13 years, rising to 10 years for someone resident for 20.
The UK is still tightening. Since April 6, 2026, business and agricultural property relief at 100% has been capped at a combined £2.5 million, and most unused pension funds fall into the estate from April 6, 2027.
🇮🇹 Italy taxes a resident’s worldwide estate, though lightly for close family: 4% for a spouse or child above €1 million each. Its flat tax regime removes even that, since foreign assets of those who pay the €300,000 annual charge pass free of Italian gift and inheritance tax.
🇵🇹 Portugal has no inheritance tax as such. A 10% stamp duty applies to Portuguese assets only, and spouses, children, grandchildren, and parents are exempt. For most Golden Visa families, the Portuguese bill on death is close to zero.
🇪🇸 Spain taxes the heir, not the estate. A Spanish resident pays on everything he inherits, wherever it comes from, while a non-resident pays only on Spanish assets. Since 2021 legislation, non-residents from outside the EU can also claim regional allowances, which in some regions cut the bill for children to a fraction of the state rate.
🇬🇷 Greece charges 1% to 10% for spouses, children, and parents after a €150,000 allowance, on Greek property whoever owns it. A Golden Visa holder’s Athens apartment is in scope; his foreign portfolio is not, unless he becomes resident.
🇫🇷 France taxes the worldwide estate of a resident and, separately, any heir who has lived in France for six of the previous 10 years. Children pay up to 45% after a €100,000 allowance. Unrelated heirs pay 60%.
🇮🇪 Ireland charges 33% on anything above €400,000 received from a parent, and the lifetime threshold counts every gift and inheritance since 1991. A non-domiciled resident’s foreign assets stay outside the tax until he has been resident for five consecutive years.
What the CBI Countries Charge
Most citizenship by investment states charge nothing at death, which is why the bill usually comes from somewhere else.
The five Caribbean programs levy no inheritance tax, estate duty, or death duty. Grenada is typical: its property transfer tax applies to sales and gifts during life, not to property passing on death. 🇻🇺 Vanuatu has no inheritance tax either.
🇲🇹 Malta has no inheritance tax but charges 5% duty when Maltese real estate passes on death and 2% on shares in Maltese companies. 🇨🇾 Cyprus abolished its estate duty in 2000.
🇦🇪 The UAE charges no inheritance tax, but its succession rules can still decide who inherits. For non-Muslims, Federal Decree-Law 41 of 2022 gives the surviving spouse half the estate by default and splits the rest equally among the children. A will registered with the DIFC Wills Service or the Abu Dhabi Judicial Department overrides that default.
🇹🇷 Turkey is the exception, and the one CBI program whose passport adds a tax. Article 1 of its Inheritance and Transfer Tax Law covers property belonging to Turkish citizens wherever it is, as well as anything located in Turkey. An investor who naturalizes therefore brings his worldwide estate into scope.
The rates are modest. In 2026, each child’s share is exempt up to roughly TL 2.9 million, and inheritances are taxed from 1% to 10% above that. Gifts run from 10% to 30%, halved between parents, spouses, and children.
Where a Second Passport Does Count
Tax and succession law are separate questions. Tax decides how much the state takes, while succession law decides who gets the rest, and on that second question a new citizenship can matter a great deal.
The EU Succession Regulation lets a person choose the law of any nationality he holds, either when he makes the choice or at death, to govern his entire estate. Without a choice, the law of his last habitual residence applies.
For investors living in Spain, Italy, or Portugal, that matters. All three reserve a fixed share of the estate for children, and a Golden Visa holder who also holds a Caribbean passport can choose that country’s law instead. Ireland and Denmark do not apply the regulation.
The regulation does not ask how a nationality was acquired, Lozie notes, so a passport bought through an investment program qualifies, with no need to live in that country.
Still, “a choice of law resting on a passport that sits in a drawer is no doubt vulnerable,” he says. The more dependable routes, in his view, are to move yourself or move your assets: living in Malta for real usually brings in Maltese law, where the children’s fixed share is lighter than on most of the Continent, “but a sham move can be ignored.”
A move has to show in daily life. Johnny Hallyday, a French singer, “had a Los Angeles home and considered himself to be a US resident, yet a French court found his habitual residence was France,” Lozie says. “A residence is judged on the facts of a life, not on the address in the documents.”
The election has two limits. It changes nothing about tax, which the regulation expressly leaves to national law, and courts can still set aside a chosen law whose result they consider contrary to public policy.
Lozie expects courts in Malta and elsewhere in the EU to respect a valid choice and to refuse a foreign rule only “if the result for that family is plainly unacceptable.” In 2017, France’s highest court confirmed that a law with no fixed share for children is not unacceptable in itself. The cases concerned the estates of composers Maurice Jarre and Michel Colombier, who lived in California.
Courts may look harder, he says, if a young or dependent child is left with nothing, or where a religious rule gives a daughter half a son’s share or treats heirs differently by faith. “Here, public policy is likely to protect the disadvantaged heir.”
🇫🇷 France tested that limit. A 2021 law gave children a compensatory claim on French assets when a chosen foreign law left them nothing, and the European Commission received several hundred complaints. In a June 2026 response, Paris said the claim applies only where the foreign law offers no protection of any kind, and accepted that English family-provision law counts.
Whether a particular CBI country’s law offers that protection is a question to settle before writing the will, not after.
Five Checks Before It Matters
- Which clock is still running? Germany, the Netherlands, Japan, and Greece keep counting after you leave, and the UK tail can last a decade. A new passport does not stop any of them.
- Where do the heirs live? France, Spain, Ireland, and Germany can tax a resident heir even when the parent never lived there. The US taxes nothing on a foreigner’s foreign estate but requires a US heir to report inheritances above $100,000.
- Where are the assets? A foreigner holding US shares or US real estate directly gets only a $60,000 exemption before the 40% top rate applies. The same holding through a non-US company is generally outside the tax.
- Does the new citizenship add a tax? In the Caribbean, Vanuatu, and Malta, it does not. In Turkey, it brings the worldwide estate into scope.
- Is there a will for each country that holds assets? UAE defaults apply without one, and a choice of law under the EU regulation has to be made in writing to count.
The pattern runs one way. Investors buy a second passport for mobility, and the inheritance bill follows the life they actually lead: where they live, where their children settle, and which citizenship they started with.
