Inheritance — the formal legal procedure for transferring assets after the owner's death. It is initiated by the opening of the estate, runs through notarial channels and is governed by the law of the jurisdiction in which each asset is situated. The procedure involves valuation of the estate, allocation of compulsory shares (under civil law systems), payment of inheritance tax in each country where the assets are located, and registration of the transfer to the heirs. The typical timeline runs from 6 months to 2 years; where multiple jurisdictions are involved, parallel procedures run with mutual legalisation of documents.
A formal inheritance procedure is heavily regulated and often disadvantageous for owners with international wealth. Until the process is complete, a significant share of the estate is effectively frozen — bank accounts are blocked, transfer of real estate requires judicial or notarial action, company shares cannot be sold. Inheritance taxation in a number of jurisdictions is heavy (Germany 7-50%, France up to 60%, the United Kingdom 40%), and reduced personal allowances for non-residents often increase the effective burden further. The procedure is also public, which is incompatible with the level of confidentiality HNWI families typically maintain.
A separate complication is the conflict of legal systems. Assets scattered across different countries are inherited under the rules of each situs jurisdiction, and those rules differ materially: forced-heirship shares (légitime / Pflichtteil) under civil-law systems, formal requirements for a valid will, recognition of foreign marriages and marital contracts, the surviving spouse's entitlements, and procedures for the legalisation of documents. A will valid under Russian law may be only partly recognised by a German, French or Italian court — and vice versa. In an international configuration the testator's wishes may not in fact be executed: they pass through the public-policy filter of each country in which assets are located, and absent a pre-structured arrangement the actual outcome often diverges from the owner's intentions.
Standard practice is therefore to structure the transfer before death, so that assets either fall outside the estate altogether or pass through it in the most efficient form for the family. The main instruments: lifetime gift (Schenkung) with the use of periodically renewing tax-free allowances; family corporate structure (Family GmbH, Familienpool) — transfer of shares in a holding entity rather than the underlying assets; private foundation (Stiftung — Liechtenstein, Austria; Foundation — Panama, Curaçao) — assets are removed from the founder's personal estate; trust (common law jurisdictions) — sits outside the formal estate; joint ownership with right of survivorship in jurisdictions where it is recognised; life and accumulation insurance with named beneficiaries — the pay-out is excluded from the estate in many systems.
The choice of instrument depends on the jurisdiction in which each asset is situated, the tax residency of the testator and the heirs, the family configuration, the nature of the assets (real estate, business interests, portfolio, personal property) and the planning horizon. No universal structure exists; each family is analysed individually.
