# Succession Planning: Wills, Multi-Jurisdiction & Forced Heirship > Forced heirship vs. freedom of testation, lex situs for cross-border assets, choice of law under Brussels IV (Reg 650/2012), probate and inheritance tax—and how to plan. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-05T08:28:00.000Z Canonical: https://wiki.private.law/en/succession-planning Topics: structures Jurisdictions: global Semantic tags: company Article type: hub --- ## 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 ties of the deceased, and a single will cannot cover it all. This page is a domain map: from here you can navigate to any of the topics below. > 🍓 Succession planning is a system of six elements: applicable law, forced heirship, taxes, structures (foundations and trusts), documents and continuity. A weak link in any of them destroys the entire plan. > 🧭 **Inheritance Navigator** — enter your citizenship, residences and assets and get a map of your case in a minute: [wiki.private.law/en/legacy](http://wiki.private.law/en/legacy) ## Law and Conflicts > 🔗 **Related** > [Applicable Law and Brussels IV](https://wiki.private.law/en/succession-applicable-law) · [Forced Heirship](https://wiki.private.law/en/forced-heirship) · [Domicile and Residence](https://wiki.private.law/en/domicile-residence-succession) · [Recognition of Trusts (Hague)](https://wiki.private.law/en/trust-recognition-hague) · [European Certificate of Succession](https://wiki.private.law/en/european-certificate-succession) · [Intestate Succession under Russian Law](https://wiki.private.law/en/russian-intestate-succession) 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. ## Instruments: Foundations, Trusts, Holdings > 🔗 **Related** > [Russian Personal/Succession Fund](https://wiki.private.law/en/russian-personal-fund) · [Private Foundations](https://wiki.private.law/en/private-foundations) · [How Trusts Work](https://wiki.private.law/en/trust-basics) · [Types of Trusts](https://wiki.private.law/en/trust-types) · [Trustee and Protector](https://wiki.private.law/en/trustee-protector) · [Private Trust Company](https://wiki.private.law/en/ptc) · [Asset Protection Trusts](https://wiki.private.law/en/asset-protection-trusts) · [Family Holding](https://wiki.private.law/en/family-holding-succession) · [Family Office](https://wiki.private.law/en/family-office) 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 > 🔗 **Related** > [Inheritance Tax Map by Country](https://wiki.private.law/en/inheritance-tax-map) · [US Estate Tax and US-Situs](https://wiki.private.law/en/us-estate-tax) · [UK IHT and Trusts](https://wiki.private.law/en/trusts-inheritance-tax) · [Gift Tax](https://wiki.private.law/en/gift-tax-lifetime-gifting) · [Trusts and CFC (Russian Beneficiaries)](https://wiki.private.law/en/trust-taxation-russia-cfc) 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 > 🔗 **Related** > [Wills and Probate](https://wiki.private.law/en/multi-jurisdiction-wills) · [Russian Inheritance Contract](https://wiki.private.law/en/russian-inheritance-contract) · [Incapacity Planning](https://wiki.private.law/en/incapacity-planning) · [Minor Heirs and Guardianship](https://wiki.private.law/en/minor-heirs-guardianship) · [European Certificate of Succession](https://wiki.private.law/en/european-certificate-succession) 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 > 🔗 **Related** > [Business Succession](https://wiki.private.law/en/business-succession) · [Foreign Real Estate](https://wiki.private.law/en/foreign-real-estate-succession) · [Foreign Accounts and Portfolios](https://wiki.private.law/en/foreign-accounts-succession) · [Life Insurance](https://wiki.private.law/en/life-insurance-succession) · [Crypto and Digital Assets](https://wiki.private.law/en/crypto-inheritance) 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 > 🔗 **Related** > [Family Charter](https://wiki.private.law/en/family-charter) · [Family Office](https://wiki.private.law/en/family-office) · [Family Holding](https://wiki.private.law/en/family-holding-succession) · [Business Succession](https://wiki.private.law/en/business-succession) · [Succession Navigator](https://wiki.private.law/en/legacy) Capital survives generations only with rules: governance sets who makes decisions and how, and structures execute them. ## Typical Scenarios ### Family in Russia, Assets Abroad > 🔗 **Related** > [Wills and Probate](https://wiki.private.law/en/multi-jurisdiction-wills) · [Foreign Real Estate](https://wiki.private.law/en/foreign-real-estate-succession) · [Foreign Accounts](https://wiki.private.law/en/foreign-accounts-succession) 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 > 🔗 **Related** > [Domicile and Residence](https://wiki.private.law/en/domicile-residence-succession) · [Applicable Law](https://wiki.private.law/en/succession-applicable-law) Several countries of residence mean several claimants to the applicable law and tax. Fix the centre of life; in the EU, choose the law of nationality in the will (Regulation 650/2012); for the UAE — a DIFC/ADGM will. More: Domicile and Residence, Applicable Law. ### US Assets Held by a Non-Resident > 🔗 **Related** > [US Estate Tax](https://wiki.private.law/en/us-estate-tax) · [Life Insurance](https://wiki.private.law/en/life-insurance-succession) US company shares and US real estate face estate tax of up to 40% with a threshold of just $60,000. 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 > 🔗 **Related** > [Business Succession](https://wiki.private.law/en/business-succession) · [Family Holding](https://wiki.private.law/en/family-holding-succession) · [Russian Personal Fund](https://wiki.private.law/en/russian-personal-fund) A company stake is not cash: 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, Russian Personal Fund. ## 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 > 🔗 **Related** > [Succession Navigator](https://wiki.private.law/en/legacy) · [Singapore](https://wiki.private.law/en/singapore-hub) · [Private banking](https://wiki.private.law/en/private-banking) · [Banks](https://wiki.private.law/en/banks) - [Succession Navigator](https://wiki.private.law/en/legacy) — 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 > ⚙️ A succession plan is not a one-time document but a living system: it is reviewed with every major change in the family—marriage, birth, relocation, sale of a business. > 💡 A quick assessment of your situation by country and assets is provided by the [Legacy Navigator](https://wiki.private.law/en/legacy). This material is for reference purposes and does not constitute individual legal advice. --- --- ## Factual claims - Where it all begins: which law governs succession and where forced heirship applies. - 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. - Several countries of residence mean several claimants to the applicable law and tax. - US company shares and US real estate face estate tax of up to 40% with a threshold of just $60,000. - With assets in several countries, parts of the estate follow different laws; a single will is either not recognised or stuck in legalisation. - 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. - 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.