Why UK nationals in Portugal are reassessing inheritance tax and succession planning

For many British nationals living in Portugal, estate planning has long relied on a clear understanding of how the UK’s inheritance tax (IHT) system worked. 

However, a significant shift introduced in April 2025 has prompted many UK expats to reconsider their existing wealth and succession strategies.

The UK has moved away from its long-standing domicile-based inheritance tax system that places greater emphasis on long-term UK residence.

While the change may sound technical, its implications could be significant for internationally mobile families, particularly those who hold assets in more than one jurisdiction.

A changing framework for UK inheritance tax

Under the previous system, domicile played a central role in determining how inheritance tax applied to individuals and their estates. 

With the shift to a residency-based framework, HMRC may now assess inheritance tax exposure differently depending on factors such as residency history and ongoing UK connections.

As a result, assets that were previously assumed to sit outside the UK inheritance tax scope may now be reassessed. This can include pensions, UK property, investment portfolios and internationally held assets that have links to the UK.

Why succession planning is back in focus

For many British nationals, succession planning was put in place years ago based on the rules and assumptions that applied at the time. The recent changes mean those arrangements may now need to be reassessed.

Paul Stannard, Chairman and Founder of Portugal Pathways, said: “We’re seeing more families increasingly reviewing how the residency-based system may affect long-term inheritance tax exposure and which assets could potentially fall within the UK tax scope. 

“Questions are also being raised about whether existing pension arrangements and estate structures continue to function as originally intended.

“Because of this, early and informed review with experienced cross-border advisers has become increasingly important.”

The growing role of structured planning

As the environment evolves, many UK nationals abroad are revisiting established planning structures that are often used to help manage inheritance tax exposure and simplify cross-border wealth arrangements.

Matt Firman, CEO at St. James Global, who specialises in cross-border wealth planning for internationally mobile UK families, said: “Structures such as Self-Invested Personal Pensions (SIPPs), Qualifying Non-UK Pension Schemes (QNUPS) and offshore trusts have come back into focus as families explore how they may fit within the new framework. 

“These types of arrangements may help in managing exposure, maintaining control over succession planning, and organising internationally held assets more efficiently.

“For families with UK-linked assets or beneficiaries, careful structuring may also help reduce complexity when managing wealth across different jurisdictions. However, the suitability of any approach depends on an individual’s circumstances, which is why many expats are seeking specialist guidance.”

An opportunity to gain expert insight

Cross-border estate planning often involves navigating several legal and tax systems at once. 

Those looking for a clearer understanding of these changes may benefit from attending an upcoming expert online briefing, hosted by Portugal Pathways alongside Matt Firman from St James Global, designed specifically for UK nationals living in Portugal.

The live session will explore how succession planning strategies are being adapted to the new residency-based framework, how internationally held assets may now be assessed and what practical questions families should be asking their advisers.

The briefing takes place on Wednesday, 18th March, 2026, at 10:00 AM (Lisbon Time) and will feature experienced cross-border planning specialists who have supported many UK families in Portugal with estate and wealth planning.

Attendees will also have the opportunity to put their own questions to the panel and leave with practical guidance relevant to their circumstances.

To register for Portugal Pathways’ upcoming webinar, click here.

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About Portugal Pathways

‍‍Portugal Pathways has supported hundreds of Golden Visa residency-by-investment applications and provides expert guidance through its professional supply chain network on estate planning, wealth management, Golden Visa and tax optimisation, including post-NHR / IFICI tax regime planning, as well as private healthcare, money transfers and bespoke relocation and luxury real estate solutions to enhance life and investment in Portugal

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Disclaimer: The information on the Portugal Pathways and Portugal Investment Owners Club (P Club for short) websites and in email communications is for general informational purposes only and should not be construed as legal, tax, or financial advice. You should consult and check with a qualified professional advisor before relying on any information provided on this website or in email communications. As it relates to investments in Golden Visas or other wealth management solutions offered by regulated and professional advisors, it is important to note that past performance is no guarantee of future returns. Private equities can be highly illiquid and come with risk and should always be under professional independent advice. Golden Visa investments need to be held for 6 to 7 years to allow for permanent citizenship/passport in the EU.

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