Estate & Succession Tax Planning Specialist

Hong Kong Has No Estate Tax. But Your Foreign Assets Might.

Hong Kong abolished estate duty in 2006 — a fact that comforts many residents until they discover that the UK, US, Australia, and most of Europe still levy inheritance or estate taxes on assets situated in those countries, or on individuals who remain domiciled there. Planning this early makes all the difference.

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0% HK estate duty since Feb 2006
40% UK IHT / US estate tax maximum rate
55% Japan inheritance tax maximum rate

Estate & Succession Tax Planning Specialist

Hong Kong abolished estate duty in 2006 — a fact that comforts many residents until they discover that the UK, US, Australia, and most of Europe still levy inheritance or estate taxes on assets situated in those countries, or on individuals who remain domiciled there. Planning this early makes all the difference.

⚠️

⚠ Common Misconception: Zero HK Estate Duty Does Not Mean Zero Exposure

Most HK residents have assets in multiple countries — overseas property, foreign investment accounts, foreign pensions — or have family members resident in other jurisdictions. Those overseas assets are subject to the estate and inheritance tax rules of the countries where they are situated or where the owner/beneficiary is resident/domiciled. A UK property owned by a HK resident is within the UK IHT net. A US brokerage account is within the US estate tax net. HK's zero duty only protects HK-sited assets.

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以下の税務問題でお困りではありませんか？

Overseas Property & Estate Duty

UK property subject to 40% IHT above the nil-rate band, US assets taxed at up to 40% for non-residents above US,000, and Australian state probate duties — many HK residents are unaware of these exposures.

⚠ Risk: Unexpected tax bill of 40% or more on overseas assets on death

UK Domicile & IHT Exposure

UK IHT at 40% applies to worldwide assets of UK-domiciled individuals. Many HK residents retain UK domicile of origin or have acquired it through long residence. The deemed domicile rules extend the net years after leaving.

⚠ Risk: Worldwide estate taxed at 40% — not just UK assets

Trust Structures Without Tax Review

Trusts established in one jurisdiction may trigger unexpected tax in another. Discretionary trusts, excluded property trusts, and offshore trusts all have specific cross-border implications that must be planned for.

⚠ Risk: Trust distributions triggering unforeseen tax in beneficiary jurisdictions

Gift Taxation in Home Jurisdictions

Many HK parents make significant lifetime gifts to children overseas. The US and some European countries tax gifts made by or to connected persons. Even in HK, gifts can be treated as income in certain business or employment contexts.

⚠ Risk: Gift tax liability for donor or recipient in overseas jurisdiction
対象者

対象となるお客様

HK Residents with UK Property

Owners of UK residential or investment property who need to understand and mitigate their IHT exposure.

HK Residents with UK Domicile

British nationals who moved to HK but may still be within the UK IHT net on worldwide assets.

Families with US-Connected Members

Families including US citizens, green card holders, or individuals with US assets facing estate and gift tax exposure.

Beneficiaries Receiving Overseas Inheritances

HK residents receiving inheritances from overseas estates needing to understand obligations and HK tax treatment.

Business Owners Planning Succession

Business owners transferring HK companies or regional holding structures to the next generation tax-efficiently.

サービス内容

サービス内容

Multi-Jurisdictional Estate Assessment

We map your entire asset base and identify the estate or inheritance tax exposure in each jurisdiction where assets are held or family members reside.

Asset inventory, domicile analysis, worst-case estate tax calculation, priority planning recommendations

Trust Structuring & Tax Review

Advice on the tax consequences of establishing trusts in various jurisdictions, review of existing trust deeds for unexpected tax triggers.

Discretionary trusts, excluded property trusts, offshore trusts, distribution tax planning

Life Insurance-Linked Estate Planning

Properly structured life insurance policies can provide liquidity to pay estate taxes and remove policy proceeds from the taxable estate entirely.

Policy-in-trust structuring, premium gifting strategy, IHT payment provision planning

Lifetime Gifting Programme

Multi-year gifting programmes using annual exemptions, potentially exempt transfers, and business property reliefs to gradually reduce the estate.

Annual exemption strategy, PET planning, business property relief, gift with reservation issues

Overseas Probate Tax Advisory

Advice on probate tax implications in each jurisdiction, coordination with overseas counsel, and tax-efficient administration sequencing.

Multi-jurisdiction probate planning, double taxation treaty analysis, overseas counsel coordination
ご利用の流れ

シンプル・効率的・プロフェッショナル

1

Confidential Discovery Meeting

Private conversation to understand family composition, asset base, residency history, existing wills and trusts, and planning objectives.

1–2 hours
2

Estate Exposure Mapping

Comprehensive estate tax exposure map showing each asset, applicable tax regime, estimated exposure, and available reliefs — coordinated with overseas counsel.

2–3 weeks
3

Planning Recommendations Report

Detailed written report with specific recommendations, quantified tax savings, and implementation timelines prioritised by impact and urgency.

1–2 weeks
4

Implementation & Annual Review

Work alongside your solicitors and trustees to implement structures, with annual reviews to ensure the plan remains current as legislation and circumstances evolve.

Ongoing
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Case Study

UK-Domiciled HK Resident — IHT Restructuring

Over £650,000 IHT avoided 節約額
  • British national in HK for 15 years, still UK-domiciled — entire worldwide estate within IHT net
  • Restructured over two years using lifetime gifts and excluded property trust
  • Potential IHT reduced from over £800,000 to under £150,000
"TAX.hk's assessment revealed I was still UK-domiciled. We restructured and reduced potential IHT from over £800,000 to under £150,000."
C
確認済みクライアント Case Study
Case Study

Multi-Jurisdiction Family — HK, Australia & Japan

HKM+ estate tax reduction 節約額
  • Family with assets in HK, Australia, and Japan
  • Combined potential estate tax exposure of over HK million identified
  • Reduced to under HK million through trust structures and gifting programme
"TAX.hk produced a comprehensive assessment and then reduced the combined exposure from HKM to under HKM. Worth every dollar."
C
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よくある質問

よくある質問

ご質問への迅速な回答

Because estate planning in 2025 is almost never purely about Hong Kong. Most HK residents have assets in multiple countries or family members in other jurisdictions. Those overseas assets are subject to local estate and inheritance tax rules. A UK property owned by a HK resident is within the UK IHT net (40%). A US brokerage account is within the US estate tax net (up to 40% above US,000 for non-residents). HK's zero duty only protects HK-sited assets.
Potentially, yes. UK IHT is based on domicile, not residence. If you were born in the UK, you remain UK domiciled unless you have permanently abandoned all intention of returning and established a domicile of choice elsewhere. Merely living in HK for 10 years is not sufficient if you still have UK property, family, or intentions of returning. The deemed domicile rules can also apply for a transitional period after departure.
Trusts serve multiple purposes: assets settled into a properly structured trust may be removed from the settlor's taxable estate — particularly important for UK IHT where gifts to discretionary trusts are potentially exempt transfers if the settlor survives 7 years. Common structures include offshore discretionary trusts, UK excluded property trusts for non-UK assets, and life insurance trusts where policy proceeds pass outside the estate entirely.
Hong Kong has no gift tax — gifts between individuals are not subject to tax (unless involving HK real property where stamp duty applies). However, the tax position in the recipient's country of residence is entirely different. UK beneficiaries may face IHT consequences if the donor is UK-domiciled. US beneficiaries may need to report large foreign gifts. Japanese beneficiaries may face Japanese gift tax.
Assuming that HK's lack of estate duty means there is no planning to do. This leads families to accumulate overseas property and international connections over decades without mapping the estate tax exposure. By the time planning is needed — typically at a medical crisis — it may be too late. UK trusts require the settlor to survive 7 years for full IHT relief. Starting 10 years too late means the most powerful tools are unavailable.

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関連サービス

Business Succession Tax Planning Family Business Owners Planning Intergenerational Transfer
Cross-Border Tax Specialist HK-Mainland Cross-Border Professionals
Charitable Giving Tax Specialist Donors & Philanthropic Individuals
Expat Tax Specialist Foreign Nationals Working in Hong Kong

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