Cross border inheritance often throws up complex tax issues. UK Inheritance Tax or IHT is due if the deceased was ‘domiciled’ (permanently resident for tax purposes) in the UK or if the person left assets that are located in the UK, for example real estate or a bank account.

Similar rules apply in other countries, for example in Italy, Spain and Germany. 

Where there are assets in multiple jurisdictions tax liabilities can arise simultaneously in more than one of such jurisdictions. Think for example of a person who inherits from a UK domiciled person who had a bank account in Italy. We help our clients understand if tax be paid in Italy or in the UK and we challenge local tax authorities when the unduly levy taxes in these situations.