Global Mobility and Estate Planning: Supporting Expatriate Employees

Executive Summary

Global mobility programmes routinely address tax equalisation, healthcare, relocation, and schooling, yet systematically neglect estate planning -- exposing employers to duty-of-care gaps and expatriate employees to material financial risk. Three converging developments make this omission untenable for HR professionals. The residence-based inheritance tax regime from 6 April 2025 means international assignment duration directly determines an employee's IHT exposure on worldwide assets.¹ From April 2027, unused pension funds and most pension death benefits enter IHT scope, though death-in-service benefits from registered pension schemes remain excluded.² Cross-border succession complexity -- forced heirship rules, the EU Succession Regulation (which the UK never adopted), and the need for jurisdiction-specific wills -- creates risk that generic domestic benefits advice cannot address.³ With over 80% of multinational employers planning to maintain or increase international assignments, and 4.8 million UK nationals living abroad, global mobility managers require a framework for integrating estate planning into expatriate benefits strategy.⁴⁵

1. The Estate Planning Blind Spot in Global Mobility

International assignment programmes have achieved considerable sophistication in tax compliance, immigration processing, and compensation structuring. The WTW 2025 Global Mobility and Expatriate Benefits Survey, based on 259 multinational respondents, confirms that 84% of employers still rely on long-term assignments of 12 months or more, with top objectives spanning business expansion (65%), skills transfer (61%), and talent development (60%).⁴ Mercer's 2025 Worldwide Survey of International Assignment Policies and Practices reinforces the scale, with nearly 350 participating organisations.⁶ Yet neither survey measures estate planning as a benefit category, and no major HR publication has addressed estate planning as a component of global mobility strategy.

This gap is not merely academic. IHT receipts reached a record GBP 8.2 billion in 2024-25, with GBP 7.1 billion collected in the first ten months of 2025-26 alone -- GBP 0.1 billion ahead of the prior year.⁷ The nil-rate band remains frozen at GBP 325,000 and the residence nil-rate band at GBP 175,000, both extended to April 2030-31.⁸ With approximately 4.8 million UK nationals living overseas -- the largest populations in Australia (23%), the United States (19%), and Canada (9%) -- and British net migration negative at 109,000 for the year ending June 2025, the intersection of international mobility and estate tax exposure affects a substantial workforce segment.⁵

Three legislative developments have transformed estate planning from a private concern into a global mobility compliance issue. First, the Finance Act 2025 (Schedule 13) replaced the domicile-based IHT system with a residence-based framework from 6 April 2025, making assignment duration the determinative factor for IHT exposure.¹ Second, from 6 April 2027, most unused pension funds and pension death benefits will be included in the estate for IHT purposes, altering the estate planning value of employer pension contributions for internationally mobile staff.² Third, the UK's non-adoption of the EU Succession Regulation (Brussels IV) means that cross-border succession for UK nationals with overseas assets operates under private international law rules that frequently conflict with forced heirship regimes in common assignment destinations.³ For global mobility managers, the business case is threefold: mitigating employer duty-of-care exposure, strengthening talent attraction and retention for international roles, and ensuring that benefits packages serve employee wellbeing in its fullest sense.

2. How the Residence-Based Inheritance Tax Regime Affects International Assignments

2.1 The Long-Term UK Resident Test

The Finance Act 2025 introduced the long-term UK resident (LTR) test, effective from 6 April 2025.¹ An individual is an LTR if UK tax resident for at least 10 of the previous 20 tax years, regardless of common law domicile.⁹ For internationally mobile employees, the consequence is direct: an inbound assignee who accumulates 10 years of UK tax residence brings worldwide assets into IHT scope. The previous domicile-based system, which required analysis of intention and personal connections, has been replaced by a mechanical, year-counting test that global mobility teams can track and forecast.

The Statutory Residence Test (SRT), established by Finance Act 2013 (Schedule 45), determines UK tax residence for each individual tax year.¹⁰ For outbound assignees, the third automatic overseas test is the primary mechanism for ceasing UK tax residence: it requires full-time overseas work, fewer than 91 UK days, fewer than 31 days working three or more hours in the UK, and no significant break from overseas work.¹⁰ Split year treatment is available when an assignment starts or ends during a tax year (Cases 1-3 for departures, Cases 4-8 for arrivals).¹⁰ The 183-day threshold triggers automatic UK residence, though days may be reduced for exceptional circumstances.¹⁰

For global mobility managers, the interaction between annual SRT outcomes and cumulative LTR status is the critical planning point. Each tax year of UK residence counts towards the 10-year LTR threshold. HR teams managing multi-year UK assignments should maintain a running count of qualifying residence years to identify when LTR status may crystallise -- or when an outbound assignment might pause the accumulation.

2.2 The IHT Tail for Departing Long-Term Residents

When an LTR departs the UK, worldwide assets do not immediately leave IHT scope. A graduated IHT tail applies, with duration determined by the length of prior UK residence.⁹¹¹ The tail periods are as follows:

Years of UK Residence (of preceding 20)	IHT Tail Duration
10-13 years	3 years
14 years	4 years
15 years	5 years
16-17 years	6-7 years
18-19 years	8-9 years
20 years	10 years

LTR status resets only after 10 consecutive tax years of non-UK residence.⁹ For an outbound UK employee who has been resident for 15 years, the IHT tail extends five years after departure -- meaning that even a multi-year overseas posting may not remove worldwide assets from UK IHT scope during the assignment period. Global mobility managers designing assignment terms should recognise that the duration of a UK assignment has direct, quantifiable estate tax consequences that persist well beyond repatriation.

2.3 Worked Scenarios: Inbound and Outbound Assignees

Inbound scenario: A senior operations manager from Singapore is posted to the UK on successive assignments totalling 11 tax years of UK residence. Under the LTR test, the employee's worldwide assets -- including property in Singapore and investments held elsewhere -- fall within UK IHT scope. If the employee subsequently returns to Singapore, a three-year IHT tail applies, during which worldwide assets remain exposed to UK IHT at 40% above the nil-rate band.⁹⁸

Outbound scenario: A UK-born finance director, resident in the UK for 18 of the previous 20 tax years, accepts a three-year posting to Dubai. Despite ceasing UK tax residence under the SRT (satisfying the third automatic overseas test), the IHT tail is eight years.⁹ The entire three-year posting falls within the tail period, meaning worldwide assets remain in UK IHT scope throughout the assignment. Only after the tail expires -- potentially five years after returning to the UK, if the return restarts UK residence counting -- does the employee's estate cease to be UK IHT-exposed on overseas assets.

These scenarios illustrate why global mobility teams should incorporate estate planning considerations into pre-assignment briefings and long-term workforce planning. Assignment duration is no longer merely an employment and income tax variable; it is a determinative factor for inheritance tax exposure.

3. Pension Death Benefits, Death-in-Service, and the April 2027 Changes

3.1 Pensions Entering IHT Scope

From 6 April 2027, most unused pension funds and pension death benefits will be included in the estate for IHT purposes.² The government's consultation response, published in July 2025, confirmed the following operational framework:¹²

• Personal representatives -- not pension scheme administrators -- are liable for reporting and paying IHT on pension assets
• Personal representatives may direct scheme administrators to withhold up to 50% of benefits for up to 15 months to cover potential IHT liabilities
• Existing spousal exemption and charitable exemption principles are maintained
• The government's impact assessment estimates that approximately 10,500 estates will have new IHT liability where previously they would not, and 38,500 estates will pay more IHT, with an average additional liability of approximately GBP 34,000 per affected estate²

This reform is directly relevant to the pillar update focus on pension death benefit tax rules. For global mobility managers, the implication is that employer pension contributions now carry an estate planning dimension that affects the total value proposition of the expatriate benefits package.

3.2 The Death-in-Service Distinction

The critical distinction for employer-provided benefits is that death-in-service benefits payable from registered pension schemes are excluded from IHT scope from April 2027, regardless of whether the scheme is discretionary or non-discretionary.²¹² This exclusion preserves the estate planning efficiency of employer death-in-service provisions and represents the single most significant IHT-efficient benefit that employers can offer internationally mobile employees.

Excepted group life policies, established under ITTOIA 2005 sections 481-482, provide a further estate-efficient structure. Where an employer establishes a group life assurance scheme as a trust with the employer as settlor, and benefits are paid at trustee discretion to family members or dependants, the benefit falls outside the employee's estate for IHT purposes.¹³ For globally mobile employees, the question is whether these UK-established schemes maintain their IHT-exempt status when the employee is on international assignment -- a matter that depends on the specific scheme terms and whether the benefit remains payable through the UK-registered arrangement.

Dependant's scheme pensions from defined benefit and collective money purchase arrangements are also excluded from the April 2027 IHT scope.² For employers operating defined benefit pension schemes with internationally mobile members, this exclusion may influence benefit design choices.

3.3 Overseas Pensions and QROPS Considerations

For expatriate employees, pension portability introduces additional complexity. The overseas transfer charge (OTC) of 25% applies to all transfers to Qualifying Recognised Overseas Pension Schemes (QROPS) from 30 October 2024, including transfers to EEA and Gibraltar schemes, which were previously excluded.¹⁴ An exception remains where the employee and the scheme are in the same country, or the scheme is an employer-sponsored occupational pension in the employee's country of residence.¹⁵

Payments from QROPS funded by transferred UK pension assets remain subject to UK tax rules for five years post-transfer.¹⁵ Government guidance has not yet explicitly addressed whether the April 2027 IHT pension rules apply to overseas pension schemes where the deceased was an LTR.¹⁴ This uncertainty affects globally mobile employees who have transferred UK pension rights to overseas schemes during assignments and subsequently die as LTRs. Until the Finance Bill 2025-26 provisions are finalised, practitioners advising on cross-border pension arrangements should treat QROPS IHT treatment as an area requiring specialist review.

3.4 Spousal Exemption for Cross-Border Couples

The spousal exemption operates differently for cross-border couples under the residence-based regime. Transfers from an LTR spouse to a non-LTR spouse are exempt up to GBP 325,000 only -- not the unlimited exemption available between two LTR spouses.¹⁶ A non-LTR spouse may elect to be treated as LTR to access the unlimited exemption, but this election brings the non-LTR spouse's worldwide assets into UK IHT scope.¹⁶ For expatriate couples where one partner has acquired LTR status through a UK assignment and the other has not, this cap represents a significant estate planning consideration that should form part of the assignment benefits review.

4. Cross-Border Wills and Succession Planning

4.1 The UK's Non-Adoption of Brussels IV

The UK did not adopt the EU Succession Regulation (Brussels IV, Regulation 650/2012), which governs cross-border succession for EU member states.³¹⁷ Under UK private international law rules, the law of domicile governs succession for movable property (investments, bank accounts, personal belongings), while the law of the jurisdiction where immovable property is situated (lex situs) governs succession for real estate.³¹⁸ This dual-regime approach means that an expatriate employee's estate may be governed by different laws depending on the nature and location of assets.

Under Brussels IV, EU member states apply habitual residence as the default connecting factor for succession, with an option to elect the law of nationality.³ A UK employee habitually resident in France at death would, under French law applying Brussels IV, have French succession law applied to their entire estate -- including the forced heirship provisions that reserve shares for children. The UK's non-participation means that UK courts would apply English law (as law of domicile) to movable property, while French courts would apply French law to immovable property in France and potentially to the entire estate under Brussels IV.

4.2 Forced Heirship in Common Assignment Destinations

Forced heirship rules reserve fixed shares of the estate for specified family members, regardless of the deceased's testamentary wishes. In jurisdictions where expatriate employees commonly hold assets -- whether property, investments, or bank accounts -- these rules can override a UK will for locally situated assets:³¹⁸

• France: The reserve hereditaire allocates protected shares to children: one child receives 50%, two children share 66.6%, and three or more children share 75% of the estate
• Germany: The Pflichtteil provides a compulsory share for spouses and children, calculated as half the intestacy share
• Spain: One-third of the estate is reserved for descendants under the legitima
• UAE: Sharia law applies to Muslim residents by default; non-Muslims may apply provisions under the DIFC Wills Service Centre for assets within Dubai International Financial Centre, or Federal Decree-Law No. 41 of 2022 for broader asset coverage

Global mobility managers should also recognise that diverse family structures -- including same-sex partnerships, blended families, and cohabiting couples -- may face additional complexity in forced heirship jurisdictions where such relationships are not legally recognised, further reinforcing the need for jurisdiction-specific legal advice during assignment planning.

For globally mobile employees, the practical consequence is that a single UK will may not effectively dispose of assets in forced heirship jurisdictions. Multiple wills -- one for UK assets, one for each jurisdiction with locally situated assets -- may be necessary, drafted with care to avoid mutual revocation clauses that could inadvertently invalidate one will when another is executed.¹⁸

4.3 The Hague Convention on Wills

The Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions provides a framework for recognising the formal validity of wills across 42 contracting states.¹⁹ The convention ensures that a will valid under the formalities of any connected legal system (nationality, domicile, habitual residence, or place of execution) is recognised. However, formal validity is distinct from substantive validity: the Hague Convention does not override forced heirship provisions in the governing succession law. An English-form will that is formally valid under the convention may still fail to distribute assets as intended if the applicable succession law imposes compulsory shares.

4.4 Double Taxation Relief: A Narrow Treaty Network

The UK maintains IHT double taxation conventions with only 10 countries: Republic of Ireland, the United States, South Africa, the Netherlands, Sweden, Switzerland, France, Italy, India, and Pakistan.²⁰ For the approximately 190 countries without an IHT treaty -- including common expatriate destinations such as Australia, the UAE, Singapore, Germany, Spain, China, and Hong Kong -- unilateral relief under IHTA 1984 section 159 is the sole mechanism for avoiding double taxation on death.²¹

Section 159 provides proportionate credit relief using the formula A / (A + B) x C, where A represents UK IHT, B represents overseas tax, and C represents the lesser amount.²¹ Most IHT treaties cover death transfers only; lifetime gifts (potentially exempt transfers, chargeable lifetime transfers) may not benefit from treaty relief.²⁰ The narrow treaty network means that most expatriate estates face double taxation complexity by default, reinforcing the need for pre-assignment estate planning review.

5. The HR Action Framework: Integrating Estate Planning into Global Mobility

5.1 Pre-Assignment Phase

Global mobility managers should integrate estate planning review into the standard pre-assignment briefing checklist. Specific actions include:

• LTR threshold assessment: Calculate the employee's cumulative years of UK tax residence against the 10-of-20 LTR test. For inbound assignees, forecast when the proposed assignment duration would cross the LTR threshold. For outbound UK employees, assess the IHT tail duration that will apply post-departure.⁹
• Will review: Confirm whether the employee has a valid UK will and, where the assignment destination has forced heirship rules, flag the need for a jurisdiction-specific will drafted by a local practitioner.¹⁸
• Death-in-service benefit portability: Verify that UK group life assurance and death-in-service benefits extend to the assignment jurisdiction and that beneficiary nomination forms reflect current circumstances.¹³
• Pension position summary: Document the employee's existing UK pension arrangements and assess whether the April 2027 IHT changes affect the estate planning value of employer contributions.²

5.2 During Assignment

Ongoing monitoring during the assignment period ensures that estate planning considerations remain current:

• Annual residence year tracking: Maintain a record of SRT outcomes for each tax year to monitor progress towards or away from LTR status. The 183-day threshold and third automatic overseas test outcomes should be tracked alongside day-counting records already maintained for income tax purposes.¹⁰
• Benefit review at renewal: Where assignments are extended, reassess the estate planning implications of additional qualifying residence years. An extension that pushes total UK residence from 9 to 11 years converts the employee's IHT position from non-LTR to LTR, with worldwide assets entering UK IHT scope.⁹
• Life event triggers: Marriage, divorce, birth of children, and property acquisition in the assignment jurisdiction all warrant estate planning review. Changes in family circumstances may alter both the forced heirship implications and the spousal exemption position.¹⁶

5.3 Repatriation Phase

Repatriation planning should include estate planning as a standard agenda item:

• Will update: Ensure wills are updated to reflect the repatriation: jurisdiction-specific wills for assets retained in the assignment destination should be reviewed, and the UK will confirmed as current.¹⁸
• IHT position reassessment: For employees returning to the UK, confirm the LTR status and any IHT tail implications. For employees who acquired LTR status during a UK assignment and are departing, communicate the tail period and its practical meaning for worldwide asset exposure.⁹
• Pension consolidation review: Where pension rights were transferred to overseas schemes during the assignment, assess the implications of the 25% overseas transfer charge on any reverse transfer and the five-year UK tax tail on QROPS payments.¹⁴¹⁵

5.4 Benefits Design and Wellbeing Alignment

The CIPD Health and Wellbeing at Work 2025 survey identifies financial wellbeing as a key domain within the holistic wellbeing framework.²² The survey reports that 75% of organisations provide support for caring responsibilities and 67% for bereavement, while mental health is the leading cause of long-term absence and CIPD research indicates that approximately a quarter of employees report that work has a negative impact on both mental and physical health.²² Estate planning support for expatriate employees aligns directly with this financial wellbeing framework.

Practical integration into the benefits package may include:

• Estate planning advisory access: Include will writing and IHT review within the expatriate benefits package, either through a panel of cross-border estate planning specialists or as a reimbursable expense within the relocation allowance
• Financial wellbeing education: Incorporate estate planning awareness into pre-assignment briefings and ongoing financial wellbeing programmes, framed as part of the holistic wellbeing provision rather than a standalone tax concern
• Specialist referral pathways: Establish clear signposting for when specialist cross-border legal and tax advice is required -- particularly for employees in forced heirship jurisdictions, those approaching LTR thresholds, or those with QROPS arrangements

UK employers posting employees abroad maintain Class 1 National Insurance contributions liability for 52 weeks, provided the employer has a UK place of business and the employee was ordinarily resident before departure.²³ Bilateral social security agreements with over 23 countries determine ongoing contribution obligations beyond this period.²³ The alignment of NIC obligations with estate planning considerations -- particularly where pension continuity and death-in-service benefit coverage are affected by the posting -- reinforces the case for integrated benefits management.

5.5 Comparative Estate Planning Considerations by Destination

To support assignment planning decisions, global mobility teams benefit from understanding the estate planning landscape across common expatriate destinations:

Destination	Estate/Inheritance Tax	UK IHT Treaty	Forced Heirship	Multiple Wills Likely
Australia	No inheritance tax	No	No	Advisable for property
USA	Federal estate tax (40% above USD 15m)24	Yes	Varies by state	Yes
France	Inheritance tax (5-60%)	Yes	Yes (reserve hereditaire)	Yes
Germany	Inheritance tax (7-50%)	No	Yes (Pflichtteil)	Yes
Singapore	No estate duty	No	No	Advisable for property
UAE	No inheritance tax (Sharia may apply)	No	Yes (Sharia for Muslims)	Yes
Spain	Inheritance tax (regional variation)	No	Yes (legitima)	Yes
Switzerland	Cantonal inheritance tax	Yes	Yes (federal law)	Yes
Netherlands	Inheritance tax (10-40%)	Yes	Yes (legitimate portion)	Yes
India	No inheritance tax	Yes	No (but Hindu succession rules)	Advisable

This comparative overview illustrates that most common expatriate destinations lack an IHT treaty with the UK, many impose forced heirship rules, and multiple wills are advisable for the majority of assignment jurisdictions.²⁰

Conclusion

The convergence of the residence-based IHT regime, pension death benefit taxation from April 2027, and cross-border succession complexity transforms estate planning from a private employee concern into a global mobility programme requirement. The LTR test creates a direct, mechanical link between assignment duration and worldwide IHT exposure that global mobility teams can monitor and forecast.¹ The death-in-service exclusion from IHT represents the employer benefit that retains its full estate planning value under the reformed regime, and should be positioned accordingly within expatriate benefits packages.² The UK's limited IHT treaty network -- covering only 10 of the world's approximately 200 jurisdictions -- means that most expatriate estates will face double taxation complexity that demands pre-assignment professional advice.²⁰

For HR leaders and global mobility specialists, the imperative is clear. Estate planning support should be integrated into assignment briefings, benefits packages, and repatriation processes as a standard component of the duty-of-care framework -- not as an optional addition. Organisations that embed this dimension into their global mobility programmes will mitigate compliance risk, strengthen the employee value proposition for international roles, and demonstrate the holistic approach to employee wellbeing that the CIPD framework advocates.²² In an era where 80% of multinational employers plan to maintain or increase international assignments, the organisations that address estate planning proactively will distinguish themselves in the competition for globally mobile talent.⁴

CPD Declaration

Suggested CPD credit: 60 minutes structured learning

Learning objectives:

On completion of this article, practitioners should be able to:

1. Identify how the long-term UK resident test (Finance Act 2025, Schedule 13) creates IHT exposure directly linked to international assignment duration, including the graduated IHT tail for departing residents
2. Distinguish between death-in-service benefits (excluded from IHT from April 2027) and other pension death benefits (within IHT scope) when evaluating expatriate benefits packages
3. Evaluate the estate planning risks for expatriate employees arising from cross-border succession rules, forced heirship provisions, and the UK's limited IHT treaty network of 10 countries
4. Apply a structured pre-assignment, during-assignment, and repatriation checklist to integrate estate planning review into global mobility processes
5. Assess the business case for including estate planning advisory support within expatriate benefits packages, aligned with the CIPD Health and Wellbeing at Work 2025 framework

Reflective questions:

• How would an organisation's existing global mobility checklist need to change to incorporate LTR threshold monitoring and estate planning triggers at each assignment phase?
• What additional due diligence steps should global mobility teams implement when assigning employees to jurisdictions with forced heirship rules that may conflict with UK testamentary freedom?
• How might the April 2027 pension death benefit IHT changes affect the positioning of death-in-service benefits within the expatriate value proposition?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 25 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

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• M&A Employee Benefits Integration: Estate Planning Considerations in Business Combinations

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Footnotes

Footnotes

1. Finance Act 2025 (c.8), Schedule 13 -- Inheritance Tax: long-term UK residence. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩ ↩² ↩³ ↩⁴

2. GOV.UK, Inheritance Tax -- unused pension funds and death benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

3. Russell Cooke, "Brussels IV's impact on UK succession post-Brexit." https://www.russell-cooke.co.uk/news-and-insights/news/brussel-ivs-impact-on-uk-succession-post-brexit; Kingsley Napley, "Wills and inheritance: 10 Cross-border Tips." https://www.kingsleynapley.co.uk/insights/blogs/private-client-law-blog/wills-and-inheritance-10-cross-border-tips ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

4. WTW, "Balancing cost and care in global mobility" (2025 Global Mobility and Expatriate Benefits Survey). https://www.wtwco.com/en-ch/insights/2025/12/balancing-cost-and-care-in-global-mobility ↩ ↩² ↩³

5. ONS, Long-term international migration, provisional -- year ending June 2025. https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/internationalmigration/bulletins/longterminternationalmigrationprovisional/yearendingjune2025 ↩ ↩²

6. Mercer, Worldwide Survey of International Assignment Policies and Practices (WIAPP) 2025. https://mobilityexchange.mercer.com/international-assignments-survey ↩

7. HMRC Tax Receipts and National Insurance Contributions for the UK (monthly bulletin). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩

8. GOV.UK, Inheritance Tax Thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩ ↩²

9. GOV.UK, Inheritance Tax if you're a long-term UK resident. https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

10. GOV.UK, RDR3: Statutory Residence Test (SRT) notes. https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3 ↩ ↩² ↩³ ↩⁴ ↩⁵

11. HMRC Inheritance Tax Manual, IHTM47020 -- Long-term UK residence test. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩

12. GOV.UK, Inheritance Tax on pensions: liability, reporting and payment -- Summary of responses. https://www.gov.uk/government/consultations/inheritance-tax-on-pensions-liability-reporting-and-payment/outcome/inheritance-tax-on-pensions-liability-reporting-and-payment-summary-of-responses ↩ ↩²

13. HMRC Inheritance Tax Manual, IHTM17091 -- Pensions: excepted group life policies: introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm17091 ↩ ↩²

14. GOV.UK, The overseas transfer charge -- guidance. https://www.gov.uk/government/publications/qualifying-recognised-overseas-pension-schemes-charge-on-transfers/the-overseas-transfer-charge-guidance ↩ ↩² ↩³

15. GOV.UK, Reducing tax-free overseas transfers of tax-relieved UK pensions. https://www.gov.uk/government/publications/changes-to-rules-for-overseas-pensions-and-scheme-administrators/reducing-tax-free-overseas-transfers-of-tax-relieved-uk-pensions ↩ ↩² ↩³

16. HMRC Inheritance Tax Manual, IHTM11033. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm11033; Finance Act 2025 Schedule 13. https://www.legislation.gov.uk/ukpga/2025/8/schedule/13 ↩ ↩² ↩³

17. EUR-Lex, Regulation (EU) No 650/2012 of the European Parliament and of the Council (EU Succession Regulation). https://eur-lex.europa.eu/eli/reg/2012/650/oj/eng ↩

18. Kingsley Napley, "Wills and inheritance: 10 Cross-border Tips." https://www.kingsleynapley.co.uk/insights/blogs/private-client-law-blog/wills-and-inheritance-10-cross-border-tips ↩ ↩² ↩³ ↩⁴ ↩⁵

19. HCCH, Convention on the Conflicts of Laws Relating to the Form of Testamentary Dispositions. https://www.hcch.net/en/instruments/conventions/specialised-sections/form-of-wills ↩

20. GOV.UK, Inheritance Tax: Double Taxation Relief. https://www.gov.uk/guidance/inheritance-tax-double-taxation-relief ↩ ↩² ↩³ ↩⁴

21. Inheritance Tax Act 1984, section 159. https://www.legislation.gov.uk/ukpga/1984/51/section/159 ↩ ↩²

22. CIPD, Health and Wellbeing at Work 2025 Survey Report. https://www.cipd.org/globalassets/media/knowledge/knowledge-hub/reports/2025-pdfs/8920-Health-and-wellbeing-report-2025-/ ↩ ↩² ↩³

23. GOV.UK, Guidance on Social Security abroad: NI38. https://www.gov.uk/government/publications/social-security-abroad-ni38/guidance-on-social-security-abroad-ni38 ↩ ↩²

24. IRS, Tax inflation adjustments for tax year 2026 including amendments from the One Big Beautiful Bill Act (P.L. 119-21). https://www.irs.gov/newsroom/irs-releases-tax-inflation-adjustments-for-tax-year-2026-including-amendments-from-the-one-big-beautiful-bill ↩