For British Expats in Portugal

Moving to Portugal doesn’t end your UK Inheritance Tax liability.

Whether you are preparing to leave the UK or have already made the move, the 2025 Inheritance Tax reforms mean your worldwide estate may remain within the scope of UK Inheritance Tax after departure. The length of that exposure depends on how long you lived in the UK, and can be up to ten years. Planning before you move gives you the widest range of options. Waiting until after narrows them considerably.

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The IHT Exposure

The 10-Year UK IHT Tail

Many people planning a move to Portugal assume that becoming a Portuguese resident ends their UK Inheritance Tax exposure. Under the 2025 Long-Term Resident rules, it does not. Anyone who was UK-resident for 10 of the previous 20 years remains liable for UK IHT on their worldwide assets for up to 10 years after departure. The earlier that planning begins, the more structural options remain available.

Cross-border estate planning depends on individual circumstances, residence history, asset structure and evolving legislation.

What most people assume

UK Inheritance Tax liability assumed to end on the day you become a Portuguese resident.

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What actually applies

40%

UK Inheritance Tax on worldwide assets, including Portuguese property and UK pensions, for up to 10 years after departure.

The wider pension picture: it is not only SIPPs.

A SIPP is one of the pension structures many internationally mobile British clients will recognise. Current UK proposals indicate that, from April 2027, many unused pension funds may become subject to UK Inheritance Tax as part of a deceased person’s estate. The precise treatment will depend on the pension structure and prevailing legislation at the time.

This may include SIPPs, SSAS, personal pensions, and defined contribution or money purchase schemes. The key issue is not the pension label, but whether unused value is brought into the estate calculation.

April 2027: a deadline that affects you whether you have moved yet or not.

When unused pension funds enter the UK Inheritance Tax net, a £500,000 pension pot becomes a £200,000 potential liability on top of any existing estate exposure. Those still in the UK planning their move have the greatest flexibility to structure ahead of both the departure and the rule change simultaneously.

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Our Team in Portugal

Global reach. Local expertise.

Chase Buchanan operates across 16 countries with offices from Canada to Cyprus. In Portugal, our locally based team holds dual authorisation across UK and Portuguese financial structures, meaning one regulated relationship covers both sides of your financial picture.

Our Portugal advisers bring decades of combined experience working with British expatriates on cross-border tax planning, UK pension structuring, and estate planning. Whether you are preparing your move or already living in Portugal, you will be speaking with someone who knows both systems.

If any of this resonates, our team is happy to have an initial conversation. No obligation. No pressure.

Chase Buchanan, Portugal

Urbanização Vila Sol
Lote 35, Vila Sol Plaza
Loja 6, 7 and 8
8125-307 Quarteira
Portugal

+351 308 802 691

Why the Advice Gap Matters

Four things your current advisers may not be telling you

Post-Brexit, UK financial advisers can no longer legally serve EU residents on regulated matters. Portugal-based advisers rarely have deep UK IHT expertise. The gap between these two positions is where most HNW expat estate plans quietly fail.

UK advisers and EU-resident clients: the regulatory picture

Since Brexit, many UK-regulated advisers can no longer advise EU-resident clients on regulated matters without the appropriate permissions or structure. If you are still in the UK, now is the time to establish a regulated cross-border relationship before you move, not after. If you are already in Portugal, it is worth confirming the basis on which your existing adviser continues to provide advice. This can affect regulatory protections and the framework under which advice is delivered.

The 10-year IHT tail applies even if you sell UK assets

A common assumption is that selling UK property or closing UK accounts removes the IHT exposure. It does not. The Long-Term Resident rules apply to worldwide assets regardless of where they are held. Portuguese property, offshore investments, and even assets gifted in the years before or after departure can remain within the scope of UK IHT during the tail period.

Your existing will may no longer reflect your wishes

Portugal applies forced heirship rules that mandate a proportion of the estate passes to direct family, which can conflict with wills drafted under English law. A Brussels IV election, explicitly stating that English law governs your succession, can help preserve broader testamentary freedom under English law. Without it, beneficiaries outside the direct family line may find the estate does not pass as intended.

Gifting strategies that worked in the UK may not work here

UK IHT gifting rules, including the seven-year rule and annual exemptions, continue to apply during the tail period for Long-Term Residents. However, the interaction between UK gifting rules and Portuguese stamp duty on certain transfers creates complexity that requires advice from someone who understands both systems. A gift that reduces UK IHT exposure may trigger a Portuguese tax event if structured incorrectly.

Begin the Conversation

Are you planning your move, or have you already arrived?

Either way, if you were a long-term UK resident, your worldwide estate may remain within the scope of UK Inheritance Tax for some time. Those planning their move have the most options. Those already in Portugal still have time. Both conversations start the same way.