Estate Planning in Popular Relocation Destinations: Italy, UAE, Portugal, Cyprus, and Malta

Different countries have vastly different rules on inheritance, succession, and taxation — and failing to plan can leave your heirs with unnecessary complexity, delays, and costs.

Italy’s charm comes with a civil law system and strict forced heirship rules. This means certain family members,  such as spouses and children, are entitled to fixed portions of your estate, regardless of the terms of your will. Inheritance tax rates are relatively low, but vary based on the beneficiary’s relationship to the deceased. Foreign wills are recognised if they meet Italian legal requirements, but professional advice is essential to align your estate plan with both Italian and home-country law.

The UAE operates under a mix of civil law and Sharia principles, with inheritance matters historically following Islamic law for Muslim residents. However, non-Muslims can now register wills under DIFC (Dubai International Financial Centre) or ADGM (Abu Dhabi Global Market) frameworks, allowing them to distribute assets according to their wishes. There is no inheritance tax, but local court procedures can be complex without a registered will in place. Estate planning here is not just about asset transfer; it’s about avoiding administrative delays for your heirs. (Read more about this here)

Portugal has forced heirship rules similar to Italy, meaning certain relatives have automatic rights to a share of your estate. The country does not impose inheritance tax on direct family members, but stamp duty applies to assets passed outside the immediate family. Foreign wills are generally accepted, but residency status and the EU Succession Regulation can affect which country’s law applies. Those holding assets in multiple jurisdictions should ensure their plan coordinates across borders.

Cyprus offers a relaxed lifestyle and an English-influenced legal system, but forced heirship applies unless you were born outside Cyprus or have acquired domicile elsewhere. This means part of your estate may be reserved for specific relatives. There is no inheritance tax, which is appealing for many expats, but local probate procedures still require clear documentation and proper will registration.

Malta’s civil law system also includes forced heirship rules, although they can be bypassed in certain circumstances with careful planning. There is no inheritance tax, but stamp duty applies to the transfer of immovable property and some other assets. For expats, Maltese wills can be drafted alongside foreign wills to ensure assets in multiple countries are covered without conflicting instructions.

Estate planning should be at the heart of any international relocation strategy. Each country’s laws carry nuances that can dramatically affect how your wealth is passed on.

Our global relocation experts will help with everything, from tax advice, inheritance planning, and wealth structuring to finding a home, securing residency visas, and ensuring a smooth move for your whole family. With over 25 years of experience, we deliver clear guidance and support without any unexpected fees.