Estate Planning in Ireland (UK Nationals & Cross-Border Estates)
The UK and Ireland share a common-law heritage, a common travel area and a long history of family movement in both directions. They do not share a tax system. Most cross-border estates we see — a parent in the UK, an adult child in Dublin, or vice versa — have at least one document that doesn't account for the second jurisdiction. The fix is rarely complicated. It almost never happens by default.
Two systems, one family, two tax bills
Ireland charges Capital Acquisitions Tax (CAT) on the beneficiary at 33% above thresholds that are far lower than UK nil-rate bands. The UK charges IHT on the estate at 40%. Without coordination, the same asset can be taxed twice.
Ireland's Capital Acquisitions Tax is paid by the beneficiary, not the estate. The Group A threshold (parent to child) is currently €400,000 — far below the UK's combined £1m for a married couple using the full RNRB. Above the threshold, the rate is a flat 33%. For an Irish-resident child inheriting a substantial UK estate, this can produce a significant Irish tax bill on top of any UK IHT.
The UK-Ireland double-taxation treaty on inheritance is one of the few in existence and provides genuine credit relief — UK IHT paid is credited against Irish CAT on the same asset, up to the Irish liability. But the credit only works where the planning engages the treaty mechanics correctly. Done by default, it often doesn't, and the family can end up paying full tax on both sides.
From April 2027 unused UK pensions enter the UK IHT estate. For UK-resident parents with adult children in Ireland — and for UK pensioners who relocated to Ireland — the change interacts with Irish CAT in ways that need to be modelled before, not after, the position crystallises.
Cross-border families in both directions
We see two patterns most often. First: a UK-based parent with an adult child in Dublin or Cork — the UK estate is fine for UK IHT purposes, but the Irish-resident beneficiary faces CAT exposure no one has modelled. Second: a British client who relocated to Ireland in middle age, retains a UK property and a UK pension, and has done nothing about the wills since the move. Both are fixable. Both need to be addressed in writing.
Wills, succession and the Succession Act 1965
Ireland's Succession Act 1965 grants a surviving spouse a legal right share — one-third of the estate where there are children, one-half where there are not — that overrides any contrary will provision. For British nationals resident in Ireland this can interact unexpectedly with UK estate planning. We draft the English will for UK assets and coordinate with Irish solicitors on any Irish will and the legal-right-share position.
Northern Ireland and the border counties
Northern Ireland follows English IHT rules; the Republic follows the Irish CAT system. Families with property and beneficiaries on both sides of the border face the full UK-Ireland coordination question, plus the practical realities of cross-border probate. The planning is no different in principle from any other UK-Ireland engagement, but the document logistics often need a Northern Ireland solicitor on the UK side as well as a Republic solicitor.
Where we typically come in
UK Inheritance Tax Planning
Modelled with the UK-Ireland treaty in view, the April 2027 pension change and the position of any Irish-resident beneficiaries.
Read more →English Wills (and Irish coordination)
An English will for UK assets, drafted to work cleanly with any Irish will and with the Succession Act 1965 legal-right-share position.
Read more →Lasting Power of Attorney
An English LPA for UK assets and decisions. Ireland's Enduring Power of Attorney regime is separate; both are needed for cross-border families.
Read more →Property Trusts (UK)
For UK property held by parents whose adult children are Irish-resident, a Property Trust on the UK will helps protect the underlying value and supports cleaner CAT planning on the receiving side.
Read more →What we'd actually do for you
First call is free and by video. We read what you have on the UK side, look at where beneficiaries are resident, and tell you whether the UK-Ireland treaty is currently engaged or being missed. From there we draft the English-side documents and coordinate with an Irish solicitor on the local side. For most cross-border families, this is the work that gets the Irish CAT exposure on the page properly for the first time.
Complete the Discovery first - then we'll book your free 30-minute consultation.
Common questions from clients in Ireland
My child lives in Dublin. Does that change my UK estate planning?
It changes the receiving side. UK IHT is calculated on the estate and is largely unaffected by where your beneficiaries live. But Irish CAT is calculated on the beneficiary — and your Dublin-based child faces a 33% charge on inheritance above €400,000. The UK-Ireland treaty allows credit for UK IHT against Irish CAT, but only if the planning engages the treaty properly.
I moved to Ireland from the UK. Do I still pay UK IHT?
If you remain UK-domiciled — which most British clients do for years after moving to Ireland — then yes, on your worldwide estate. The UK-Ireland treaty provides credit for tax paid on the same asset in either country, but the planning needs to be set up to use it.
Do you cover Northern Ireland as well?
Yes. Northern Ireland follows the same IHT rules as England and Wales, so the planning work is essentially the same. For families straddling the border, we coordinate with both Northern Irish and Republic of Ireland solicitors as needed.
Do I need to come to your office to work with you?
No. We work nationally — and increasingly internationally. Most of our clients in Ireland are seen by video call, with documents signed remotely or couriered when wet signatures are needed. The advice is the same. The convenience is yours.
Is Sean Kiani regulated?
Sean Kiani is a member of the Society of Will Writers and holds full Professional Indemnity Insurance. Estate planning is unregulated in the UK — which is precisely why credentials, supervision and indemnity matter.
What does a first conversation cost?
Nothing. A first call is free, confidential, and exists for one purpose: to find out whether your current arrangements still do what you think they do. If they do, we'll tell you. If they don't, you'll know exactly what's exposed and what to do about it.
Your 30 minutes. Simple. Yours.
No-obligation.
The path is simple: complete the Discovery first so we walk into the call already knowing the facts. Then in 30 focused minutes, I listen, answer your questions, and you choose if you'd like us to draw up your Inheritance Plan.
1. Start Your Discovery
Required first step. Complete the confidential financial position review so your no-obligation 30-minute consultation starts with the facts, not the basics.
2. Request a Callback
Prefer to speak first? Leave your details and we'll call you back to talk through the Discovery before you complete it.
You choose the date, time, and format - phone or online. Bring anyone you'd like.