Private client: Country Q&A tool

Search the Country Q&A in the Private Client Global Guide by question and jurisdiction.

Step 1: Check the boxes to select the questions and the jurisdictions for comparison.
Step 2: Click the "submit" button.
Step 3: Scroll down to view answers and check law stated dates for each jurisdiction.

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Taxation

Tax year and payment dates

1. When does the official tax year start and finish in your jurisdiction and what are the tax payment dates/deadlines?
 

Domicile and residence

2. What concepts determine tax liability in your jurisdiction (for example, domicile and residence)? In what context(s) are they relevant and how do they impact on a taxpayer?
 

Taxation on exit

3. Does your jurisdiction impose any tax when a person leaves (for example, an exit tax)? Are there any other consequences of leaving (particularly with regard to individuals domiciled in your jurisdiction)?
 

Temporary residents

4. Does your jurisdiction have any particular tax rules affecting temporary residents?
 

Taxes on the gains and income of foreign nationals

5. How are gains on real estate or other owned by a foreign national taxed? What are the relevant tax rates?
 
6. How is income received by a foreign national taxed? Is there a withholding tax? What are the income tax rates?
 

Inheritance taxes and lifetime gifts

7. What is the basis of the inheritance tax or gift tax regime (or alternative regime if relevant)?
 
8. What are the inheritance tax or gift tax rates (or alternative rates if relevant)?
 
9. Does the inheritance tax or gift tax regime apply to foreign owners of real estate and other assets?
 
10. Are there any other taxes on death or on lifetime gifts?
 

Taxes on buying real estate and other assets

11. Are there any other taxes that a foreign national must consider when buying real estate and other assets in your jurisdiction?
 
12. What tax-advantageous real estate holding structures are available in your jurisdiction for non-resident individuals?
 

Taxes on overseas real estate and other assets

13. How are residents in your jurisdiction with real estate or other assets overseas taxed?
 

International tax treaties

14. Is your jurisdiction a party to many double tax treaties with other jurisdictions?
 

Wills and estate administration

Governing law and formalities

15. Is it essential for an owner of assets in your jurisdiction to make a will in your jurisdiction? Does the will have to be governed by the laws of your jurisdiction?
 
16. What are the formalities for making a will in your jurisdiction? Do they vary depending on the nationality, residence and/or domicile of the testator?
 

Redirecting entitlements

17. What rules apply if beneficiaries redirect their entitlements?
 

Validity of foreign wills and foreign grants of probate

18. To what extent are wills made in another jurisdiction recognised as valid/enforced in your jurisdiction? Does your jurisdiction recognise a foreign grant of probate (or its equivalent) or are further formalities required?
 

Death of foreign nationals

19. Are there any relevant practical estate administration issues if foreign nationals die in your jurisdiction?
 

Administering the estate

20. Who is responsible for administering the estate and in whom does it initially vest?
 
21. What is the procedure on death in your jurisdiction for tax and other purposes in relation to:
  • Establishing title and gathering in assets (including any particular considerations for non-resident executors)?

  • Paying taxes?

  • Distributing?

 
22. Are there any time limits/restrictions/valuation issues that are particularly relevant to an estate with an element in another jurisdiction?
 
23. Is it possible for a beneficiary to challenge a will/the executors/the administrators?
 

Succession regimes

24. What is the succession regime in your jurisdiction (for example, is there a forced heirship regime?)
 

Forced heirship regimes

25. What are the main characteristics of the forced heirship regime, if any, in your jurisdiction?
 

Real estate or other assets owned by foreign nationals

26. Are real estate or other assets owned by a foreign national subject to your succession laws or the laws of the foreign national's original country?
 
27. Do your courts apply the doctrine of renvoi in relation to succession to immovable property?
 

Intestacy

28. What different succession rules, if any, apply to the intestate?
 
29. Is it possible for beneficiaries to challenge the adequacy of their provision under the intestacy rules?
 

Trusts

30. Are trusts (or an alternative structure) recognised in your jurisdiction? If so, how are they taxed and what is the residence status?
 
31. Does your jurisdiction recognise trusts that are governed by another jurisdiction's laws and are created for foreign persons?
 
32. What are the tax consequences of trustees (for example, of an English trust) becoming resident in/ leaving your jurisdiction?
 
33. If your jurisdiction has its own trust law:
  • Does the law provide specifically for the creation of non-charitable purpose trusts?

  • Does the law restrict the perpetuity period within which gifts in trusts must vest, or the period during which income may be accumulated?

  • Can the trust document restrict the beneficiaries' rights to information about the trust?

 
34. Does the law in your jurisdiction recognise claims against trust assets by the spouse/civil partner of a settlor or beneficiary on the dissolution of the marriage/partnership?
 
35. To what extent does the law of your jurisdiction allow trusts to be used to shelter assets from the creditors of a settlor or beneficiary?
 

Charities

36. Are charities recognised in your jurisdiction?
 
37. If charities are recognised in your jurisdiction, how can an individual donor set up a charity?
 
38. What are the benefits for individuals when setting up charitable organisations?
 

Ownership and familial relationships

Co-ownership

39. What are the laws regarding co-ownership and how do they impact on taxes, succession and estate administration?
 

Familial relationships

40. What matrimonial regimes in trust or succession law exist in your jurisdiction? Are the rights of cohabitees/civil partners in real estate or other assets protected by law?
 
41. Is there a form of recognised relationship for same-sex couples and how are they treated for tax and succession purposes?
 
42. How are the following terms defined in law:
  • Married?

  • Divorced?

  • Adopted?

  • Legitimate.

  • Civil partnership.

 

Minority

43. What rules apply during the period when an heir is a minor? Can a minor own assets and who can deal with those assets on the minor's behalf?
 

Capacity and power of attorney

44. What procedures apply when a person loses capacity? Does your jurisdiction recognise powers of attorney (or their equivalent) made under the law of other jurisdictions?
 

Proposals for reform

45. Are there any proposals to reform private client law in your jurisdiction?
 
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