Concept
Succession planning is the advance design of how capital will pass to the next generation. For an international family, it is not a single document but a system of coordinated decisions: applicable law, forced heirship, taxes, structures, documents and continuity—aligned across all countries where the family has assets and ties.
Succession is determined by the location of the asset (situs) and the personal ties of the deceased—citizenship, domicile, residence—so a single will rarely covers the whole picture. Below are the main nodes of the topic, each linking to a detailed breakdown.
Law and Conflicts
Where it all begins: which law governs succession and where forced heirship applies. Domicile and citizenship determine both the applicable law and the recognition of foreign structures—so conflicts are resolved before choosing instruments.
Succession by Jurisdiction
How the estate is divided when there is neither a will nor structures is decided by the law of the specific country: some apply a broad range of statutory heirs, others a rigid forced heirship, and others near-total freedom of testation. Below are focused breakdowns for the key jurisdictions, each with the succession-planning techniques available in that country.
Instruments: Foundations, Trusts, Holdings
The core of the plan is structures that separate ownership from benefit. They outlive the testator and hold assets under uniform rules; the choice of vehicle depends on whether it is common law or civil law, and where the beneficiaries are located.
Inheritance Taxes
Inheritance tax is highly uneven: in some places there is none, in others the rate reaches tens of percent, and a separate trap is US-situs assets of a non-resident. The route depends on the family's jurisdictions and the regime for Russian beneficiaries.
Documents and Process
Intent is embodied in documents—a set coordinated across all jurisdictions: wills and the procedure for their recognition, inheritance contracts, incapacity plans and guardianship of minors.
By Asset Type
Each asset is inherited differently: a business requires a succession plan, real estate—law of the place where it is located, accounts and portfolios—access and currency rules, and crypto—a pre-resolved question of keys.
Family and Governance
Capital survives generations only with rules: governance sets who makes decisions and how, and structures execute them. A family charter, councils and a pre-defined order of payouts to beneficiaries defuse conflicts before they reach court and keep the assets together across a change of generations.
Typical Scenarios
Family in Russia, Assets Abroad
Accounts and portfolios in the EU or UAE, real estate in Spain. A Russian notary applies the law of the property's location to real estate and Russian law to movables: the estate splits and procedures run in parallel. The working set: coordinated wills for each asset country, a forced-heirship check where the property sits, and a document pack for banks prepared in advance (apostille, translations). More: Wills and Probate, Foreign Real Estate, Foreign Accounts.
Multi-Residence: Russia + UAE or EU
Several countries of residence mean several claimants to the applicable law and to tax. Fix the centre of life; in the EU the choice of the law of nationality is fixed in the will under Regulation 650/2012 (which applies in all EU countries except Denmark and Ireland), while for the UAE a DIFC or ADGM will is drawn up on English principles. More: Domicile and Residence, Applicable Law.
US Assets Held by a Non-Resident
US company shares and US real estate face estate tax of up to 40%. A US citizen or resident has a deduction of about $15 million in 2026, while a non-resident gets only $60,000 on US-situs assets, and that threshold is not indexed. Direct holding is replaced with a blocker structure; liquidity for the tax is covered by life insurance. More: US Estate Tax, Life Insurance.
Passing a Business to Heirs
A company stake is not divided like an account balance: the charter and shareholders' agreement decide whether the heir enters the business, an executor holds management through the procedure, and a holding or personal fund removes the fragmentation problem. More: Business Succession, Family Holding, Personal Fund.
Minor Heirs
When the heirs are children, managing the assets until they come of age moves to the fore. Without an appointed guardian and a management order, a court will appoint a representative under its own rules—often in an inconvenient jurisdiction and with purely formal control over the capital. Guardianship appointments in the will help, and for substantial capital—a trust or personal fund with a clear order of payouts. More: Trusts, Private Foundations.
Regulation: EU, UAE, US
Within the EU, succession conflicts are reduced to a common rule. Regulation 650/2012 (Brussels IV), in force since 17 August 2015, determines the applicable law by the deceased's last habitual residence and allows a will to choose the law of the country of nationality—the primary tool for an expat with assets in Europe. It applies in all EU countries except Denmark and Ireland, which kept their own private international law.
For the UAE there are separate regimes for non-Muslims: DIFC and ADGM wills on English principles with their own probate. The 2025 DIFC judicial reform gave the DIFC courts exclusive jurisdiction over such wills and the issuance of probate orders, and a will can now be registered remotely through the DIFC Virtual Registry. This removes the risk of Sharia division rules being applied to local real estate and company stakes.
The US levies estate tax on any US-situs assets of a non-resident—shares in US companies, real estate, LP interests—at a rate of up to 40%. A US citizen or resident is protected in 2026 by a deduction of about $15 million, while a non-resident gets only $60,000, and the threshold is not indexed. Hence blocker structures over US assets and life insurance for tax liquidity.
Common Mistakes
One will "for everything"
With assets in several countries, parts of the estate follow different laws; a single will is either not recognised or stuck in legalisation. The fix is a coordinated set of wills that do not revoke each other.
Ignoring forced heirship
A will that violates a forced share is challengeable in that part — the plan collapses exactly where it was written "rigidly".
US securities held directly
A non-resident with US shares at a broker leaves the heirs a tax of up to 40% — the threshold has stayed unindexed at $60,000.
Crypto without a handover protocol
Keys and seed phrases do not pass through a notary: without pre-arranged access the assets are lost for good.
Powers of attorney and joint accounts as a "plan"
A power of attorney terminates on death; accounts are frozen until every heir proves their rights — the family is left without liquidity for months.
A plan without review
Relocation, marriage, birth, sale of a business — each event changes the applicable law and taxes; an unrevised plan goes stale within a couple of years.
Related Maps
- Succession Navigator — an interactive assessment of your situation
- Singapore — wealth planning and trust infrastructure
- Private banking — the banking side of substantial capital
- Banks — accounts and compliance across jurisdictions
This material is for reference purposes and does not constitute individual legal advice.