Cross-Border Estate Planning for UK-Nigeria Families
High-net-worth families with assets split between the UK and Nigeria face a uniquely complex estate planning landscape. Two inheritance tax regimes, competing succession laws, and differing probate processes demand a coordinated strategy.
For families with a footprint across both jurisdictions, the question is not simply 'how do I pass on my wealth?' — it is 'how do I ensure my wealth passes efficiently, in the right proportions, to the right people, under the right laws?'
The Inheritance Tax Exposure
UK domiciled individuals are subject to Inheritance Tax (IHT) on their worldwide assets at 40% above the nil-rate band. For those who have acquired UK property but retain strong ties to Nigeria, the question of domicile — and therefore the extent of IHT exposure — can be more complex than it first appears. A properly structured Will, combined with trust arrangements, can significantly reduce the taxable estate.
Nigerian Succession Law
Assets situated in Nigeria are governed by Nigerian law. Without a valid Nigerian Will that is properly executed and registered, assets may be distributed under customary or intestacy rules — which can produce outcomes far removed from the deceased's wishes. We recommend that clients with Nigerian assets maintain a separate Nigerian Will alongside their UK Will.
A dual-jurisdiction estate plan is not a luxury — it is a necessity for any family with meaningful assets in both countries.
GECA's Legacy Planning team has decades of experience structuring estates that span multiple jurisdictions. We work closely with UK solicitors and Nigerian notaries to ensure a coherent, legally enforceable plan that reflects your intentions fully.