Personal succession
- Wills and local grants of authority
- Property and accounts in a person’s name
- Pension and insurance nominations
- Powers of attorney
Tax & Structuring
Succession across borders
Understand how ownership, control and decision-making pass when families, businesses and assets span more than one country.
Succession is not only about who inherits. It is also about who can act, who controls the business and whether the plan still works when jurisdictions overlap.
Succession is the process of transferring ownership, responsibility, control and family decision-making over time — not simply passing assets at death.
Estate planning asks how assets and documents fit a death or an incapacity. Succession asks the wider operational question: ownership, control, management and the next person who can decide. The two overlap. They are not the same page.
The tax and probate orientation is on cross-border estate planning. Company residence and management are on company structuring.
The question
Who owns, who controls and who inherits can be three different people
An executor administers an estate. A shareholder owns shares. A director manages a company. A trustee holds assets under a deed. A beneficiary may benefit. A successor may be asked to run something. Family governance is how those roles are explained while everyone can still discuss them. International estates and businesses fail in the gaps between the roles.
Two tracks
Personal succession and business succession do not use the same documents
A will may pass a house and a shareholding. It does not, by itself, appoint a director or tell a bank who may approve a payment next week. For a business owner, the plan has to cover economic ownership and operational control.
Business succession
- Who owns the shares
- Who can act as director
- Who manages day to day
- Whether the path is family, a sale, or both
Personal assets
Personal assets still need a person who can collect them
Bank mandates, joint accounts and digital access fail quietly. The heir named in a will may not be the person a foreign bank will speak to until a local grant exists. List the assets by country, and list who can instruct each institution if you cannot.
A family business
A family business is ownership, a job, and a set of relationships
Passing a family company can mean shares to children who will not work in it, management to someone who will, and a way to fund a relative who is bought out. Those are separate designs. Tax may follow each of them. It should not be the first design.
01
Founder
02
Ownership
03
Control
04
Management
05
Successor, sale or family
The last step is a choice of path — a successor inside the family, a sale, or a split between them. The page does not prefer one.
Control
Directors and bank signatories are the people who can act on a Monday morning
If every decision needs one founder, the business pauses when that founder cannot decide. Additional directors, clear authority in the articles, and a note of who holds the bank token are operational. They are also part of succession. Where those directors live can raise a company-residence question, which belongs on the company structuring page and should be asked at the same time, not instead.
Trusts
A trust above a company moves the control question to the trustees
If a trust owns the shares, the people who can vote them are the trustees, within the deed. A protector or a settlor with reserved powers may still be the practical decision-maker. Countries that do not recognise the trust may not see the structure the family sees. Roles and recognition are on trusts. This page does not suggest adding a trust in order to pass a company on.
Property
Property succession is local, even when the family is not
A home abroad can pass under local succession rules, a local will, or a rule the family does not expect, including reserved shares for relatives where forced heirship exists. Who lives in the property, who is on the title, and who can sell it during an administration are practical questions beside any tax. Property is the buying context. The estate-planning page is the tax and probate context.
Pensions
Pension succession is often a form, not a clause in the will
Nominations decide who a scheme may pay. They go stale. The tax treatment of a death benefit can differ for the recipient’s country of residence. Pensions covers the scheme questions. Confirm the form, and confirm the tax question, before treating the will as the whole answer.
Incapacity
Succession includes the months when someone is alive and cannot decide
Emergency decision-making — a power of attorney, a deputy, a continuing director — matters before any will is read. A document made in one country may not be accepted by a bank or a land registry in another. Ask while the person can still sign what each country requires.
Liquidity
An asset that cannot be sold quickly can stall a handover
Tax, a buy-out of a sibling, or a period when the business earns less can all need cash. Shares in a private company and a house abroad are not cash. Whether life insurance, retained earnings or a sale would fund the gap is a planning question for advisers who can see the numbers. This page does not estimate the gap.
The family
Family governance is how disagreement is handled before it is a dispute
A short written understanding — who is expected to work in the business, who is an owner only, how information is shared — can sit beside the legal documents. It does not replace them. Next-generation heirs who have never seen the structure are more likely to meet it for the first time from a lawyer.
Across borders
Heirs in different countries inherit a reporting question as well as an asset
An heir’s residence can affect tax, whether they may hold the asset, and whether they can be a director. A plan that works if everyone stays put should be reread when a child moves. International heirs are a reason to coordinate wills and company documents, not a reason to prefer one country.
The file
The documents have to agree with each other
Wills, shareholder registers, articles, shareholders’ agreements, trust deeds, pension nominations, powers of attorney and a current list of signatories are the set. Cross-border positions are easier to defend, and easier to administer, when the timeline and the ownership are documented and the papers do not revoke or contradict one another.
Do not start with a structure. Start with who owns, who controls, and which documents already say so.
Due diligence
Questions worth asking about a cross-border succession
01Who owns each asset today, legally?
Ask for the name on the title, the share register and the account. Ownership is the first column. It is not the whole plan.
02Who can make decisions tomorrow if that person cannot?
Ask about directors, attorneys, executors and anyone else with a power to act. Control can fail before ownership does.
03What passes by will, and what passes another way?
Ask about pensions, insurance, joint property, companies and trusts separately.
04If this is a business, who can run it next month?
Ask who is a director, who is a signatory, and whether a shareholder agreement covers death or incapacity.
05Do the heirs live in different countries?
Ask whether they can hold the asset, report it and, where relevant, act for the company from where they live.
06Is there enough cash to pay tax or to buy out a relative?
Ask about liquidity before assuming shares or a house can simply be handed over. This page does not estimate the tax.
07Is there a buy-sell or similar agreement?
Ask what it covers, how a price would be set, and whether anyone has the means to complete it. It is a concept to review, not a template.
08What happens to key-person risk?
Ask what the business cannot do if one person is suddenly absent. Insurance may be part of that conversation. It is not a complete answer.
09Does a trust sit above the company?
Ask who, among the trustees, can vote the shares, and whether the countries involved recognise that.
10Are the wills, the articles and the deed consistent?
Ask a lawyer who can see all three. A conflict between them is a succession problem, not a drafting detail.
11Who should be told, and when?
Ask about family governance: what the next generation knows, and what is written down if there is a disagreement.
12What should be reviewed after a move?
Ask which documents are tied to a country you are leaving, and which heirs’ countries have changed.
Watch for
Handovers that cover only one of the roles
- Assuming a will appoints the next director
- Leaving a single bank signatory
- Treating children as one group when they live in different countries
- Ignoring a shareholders’ agreement that restricts transfer
- Assuming a trust is recognised where the heirs live
- Finding out about key-person dependence only when the person is absent
- Confusing legal ownership with who actually decides
Compare succession providers
Succession planning is about more than transferring assets
Succession is the process of transferring ownership, responsibility, control and family decision-making over time — not simply passing assets at death.
Compare international succession providers by family governance, family business succession, next-generation preparation, fiduciary implementation, estate-planning coordination, cross-border capability and family-office support.
A provider that is strong in trustee and fiduciary implementation may not offer the same depth of family governance or next-generation preparation as an integrated family-office adviser.
Start with the succession need
What are you trying to prepare for?
What to compare
Succession providers differ in what they actually implement
01
Family governance
Can they help formalise decision-making?
02
Business succession
Can they support ownership and management transition?
03
Next generation
Do they support preparation, mentoring or education?
04
Fiduciary implementation
Can they establish or administer trusts and structures?
05
Estate planning
Can they coordinate wills and legal planning?
06
Cross-border capability
Can they handle several jurisdictions?
07
Family office
Can they provide ongoing administration and governance support?
08
Legacy / philanthropy
Can they support long-term charitable or family legacy planning?
Filter succession providers
6 providers listed for comparison.
Equiom
Private wealth, fiduciary and succession planning provider
Private-wealth fiduciary and succession support, including trusts, foundations and family-office coordination.
- Best aligned with
- HNW families · family offices · entrepreneurs
- Global reach
- High
- Primary audience
- HNW families, entrepreneurs, family offices and advisers
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Governance-led
- Trust / fiduciary
- Exceptional
- Estate planning
- Strong
- Cross-border succession
- Strong
- Tax / legal coordination
- Multi-jurisdiction coordination
- Family office
- Strong
- Legacy / philanthropy
- Available
- Pricing model
- Request a written fee schedule
Services are delivered by relevant local entities. Succession and fiduciary outcomes are jurisdiction-specific.
Hawksford
International private client and fiduciary provider
Private-client fiduciary support for families and family businesses, including trusts, foundations and succession planning.
- Best aligned with
- HNW families · family businesses · entrepreneurs
- Global reach
- High
- Primary audience
- HNW families, family businesses, entrepreneurs and intermediaries
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Not core
- Trust / fiduciary
- Exceptional
- Estate planning
- Strong
- Cross-border succession
- Strong
- Tax / legal coordination
- Adviser coordination
- Family office
- Available
- Legacy / philanthropy
- Charitable structures
- Pricing model
- Request a written fee schedule
Succession solutions vary materially by jurisdiction, family structure and governing law.
Sovereign Group
International private-client, trust and succession provider
Private-client trust and succession planning for internationally mobile families and entrepreneurs. Next-generation programmes are not a core part of the published offering.
- Best aligned with
- International families · entrepreneurs
- Global reach
- High
- Primary audience
- Internationally mobile families, entrepreneurs and private investors
- Family governance
- Available
- Business succession
- Available
- Next generation
- Not core
- Trust / fiduciary
- Strong
- Estate planning
- Strong
- Cross-border succession
- Strong
- Tax / legal coordination
- Strong
- Family office
- Structure dependent
- Legacy / philanthropy
- Available
- Pricing model
- Request a written fee schedule
International structures must be matched to residence, domicile, tax, inheritance and regulatory rules in each relevant jurisdiction.
- Stonehage Fleming
Stonehage Fleming
International family office and family governance adviser
Family-office and governance support for international families, including family business succession and next-generation preparation. Legal, tax and fiduciary work may sit with different group entities.
- Best aligned with
- UHNW/HNW families · family businesses · founders
- Global reach
- High
- Primary audience
- UHNW/HNW families, family businesses, founders and next-generation family members
- Family governance
- Exceptional
- Business succession
- Exceptional
- Next generation
- Exceptional
- Trust / fiduciary
- Strong
- Estate planning
- Strong
- Cross-border succession
- Exceptional
- Tax / legal coordination
- In-house and external network
- Family office
- Exceptional
- Legacy / philanthropy
- Strong
- Pricing model
- Engagement-specific
Succession advice can involve legal, tax, fiduciary, investment and governance work delivered by different regulated group entities.
Vistra
Global private wealth and succession planning provider
Private-client succession and fiduciary support for international families and family offices. This is separate from Vistra’s corporate entity-management work.
- Best aligned with
- HNW/UHNW families · entrepreneurs · family offices
- Global reach
- Very high
- Primary audience
- HNW/UHNW families, entrepreneurs, family offices and business-owning families
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Available
- Trust / fiduciary
- Exceptional
- Estate planning
- Coordinates advisers
- Cross-border succession
- Exceptional
- Tax / legal coordination
- Strong
- Family office
- Strong
- Legacy / philanthropy
- Available
- Pricing model
- Request a written fee schedule
Succession structures require current tax and legal advice and ongoing compliance across the jurisdictions involved.
ZEDRA
Global private wealth, trust and succession provider
Private-wealth trust and succession support for families, family businesses and entrepreneurs, with fiduciary implementation as a central part of the published offering.
- Best aligned with
- HNW/UHNW families · family businesses · entrepreneurs
- Global reach
- Very high
- Primary audience
- HNW/UHNW families, family businesses, entrepreneurs, family offices and advisers
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Available
- Trust / fiduciary
- Exceptional
- Estate planning
- Strong
- Cross-border succession
- Exceptional
- Tax / legal coordination
- Adviser coordination
- Family office
- Strong
- Legacy / philanthropy
- Strong
- Pricing model
- Request a written fee schedule
Succession structures and legal or tax outcomes vary by jurisdiction and should be coordinated with qualified advisers.
Compare international succession providers
Short published facts only. These labels describe the provider’s own materials. They are not ratings.
A family-office governance adviser and a fiduciary trustee do not do the same job.
| Provider | Provider type | Best aligned with | Family governance | Business succession | Next generation | Trust / fiduciary | View |
|---|---|---|---|---|---|---|---|
| Fiduciary and succession | HNW families · family offices · entrepreneurs | Strong | Strong | Governance-led | Exceptional | View |
| Private client fiduciary | HNW families · family businesses · entrepreneurs | Strong | Strong | Not core | Exceptional | View |
| Private client and trust | International families · entrepreneurs | Available | Available | Not core | Strong | View |
Stonehage Fleming Stonehage Fleming | Family office and governance | UHNW/HNW families · family businesses · founders | Exceptional | Exceptional | Exceptional | Strong | View |
| Private wealth and succession | HNW/UHNW families · entrepreneurs · family offices | Strong | Strong | Available | Exceptional | View |
| Trust and succession | HNW/UHNW families · family businesses · entrepreneurs | Strong | Strong | Available | Exceptional | View |
| Provider | Best aligned with | Family governance | Business succession | Next generation | View |
|---|---|---|---|---|---|
| HNW families · family offices · entrepreneurs | Strong | Strong | Governance-led | View |
| HNW families · family businesses · entrepreneurs | Strong | Strong | Not core | View |
| International families · entrepreneurs | Available | Available | Not core | View |
Stonehage Fleming Stonehage Fleming | UHNW/HNW families · family businesses · founders | Exceptional | Exceptional | Exceptional | View |
| HNW/UHNW families · entrepreneurs · family offices | Strong | Strong | Available | View |
| HNW/UHNW families · family businesses · entrepreneurs | Strong | Strong | Available | View |
- Provider type
- Fiduciary and succession
- Best aligned with
- HNW families · family offices · entrepreneurs
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Governance-led
- Trust / fiduciary
- Exceptional
- Cross-border succession
- Strong
- Provider type
- Private client fiduciary
- Best aligned with
- HNW families · family businesses · entrepreneurs
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Not core
- Trust / fiduciary
- Exceptional
- Cross-border succession
- Strong
- Provider type
- Private client and trust
- Best aligned with
- International families · entrepreneurs
- Family governance
- Available
- Business succession
- Available
- Next generation
- Not core
- Trust / fiduciary
- Strong
- Cross-border succession
- Strong
- Provider type
- Family office and governance
- Best aligned with
- UHNW/HNW families · family businesses · founders
- Family governance
- Exceptional
- Business succession
- Exceptional
- Next generation
- Exceptional
- Trust / fiduciary
- Strong
- Cross-border succession
- Exceptional
- Provider type
- Private wealth and succession
- Best aligned with
- HNW/UHNW families · entrepreneurs · family offices
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Available
- Trust / fiduciary
- Exceptional
- Cross-border succession
- Exceptional
- Provider type
- Trust and succession
- Best aligned with
- HNW/UHNW families · family businesses · entrepreneurs
- Family governance
- Strong
- Business succession
- Strong
- Next generation
- Available
- Trust / fiduciary
- Exceptional
- Cross-border succession
- Exceptional
Different succession providers solve different problems
Family governance adviser
Helps families formalise decision-making and long-term governance. In this comparison: Stonehage Fleming, whose published governance work includes constitutions, councils and facilitated meetings.
Family business succession adviser
Focuses on ownership and management transition. Stonehage Fleming publishes this as exceptional. ZEDRA, Vistra, Equiom and Hawksford publish it as strong. Sovereign Group publishes it as available.
Fiduciary and trust provider
Implements trusts and other long-term structures. ZEDRA, Vistra, Equiom and Hawksford publish fiduciary implementation as exceptional. Stonehage Fleming and Sovereign Group publish it as strong.
Integrated family office
Coordinates family governance, wealth and administration. In this comparison: Stonehage Fleming. ZEDRA, Vistra and Equiom also publish family-office support as strong.
Private wealth and succession provider
Combines structuring, fiduciary and succession support. In this comparison: ZEDRA, Vistra, Equiom and Sovereign Group. The models are not the same.
The right provider depends on whether the challenge is governance, ownership transition, legal implementation, fiduciary administration or all of them together.
Common scenarios
Which succession situation is closest to yours?
Common situations
Situations that need more than one document
These are patterns. They are not outcomes, and they are not advice to choose a path.
A founder dies unexpectedly
Who can sign, who inherits the shares, and whether the business can trade.
A business passes to children
Ownership, jobs and any relative who will not work in it.
Heirs live in different countries
Recognition, tax and whether they can act as directors.
A family owns property internationally
Local succession rules beside the family’s other documents.
A trust sits above the operating company
Who votes the shares, and which countries recognise that.
An owner becomes incapacitated
Powers of attorney, remaining directors and bank access.
Tools
Related tools
These tools help with records and comparisons. They do not calculate tax.
Explore tax & structuring
Go deeper into a related topic
- Estate planningWills, probate and the tax connecting factors around an estate.
- Company structuringWhere a company is managed, and how that differs from who owns it.
- TrustsWhen control of assets sits with trustees rather than with the family directly.
Ownership, control and the next decision-maker are different questions?
Separate who inherits, who can sign and who runs the business before changing a structure.
WiT Access provides general information and comparison resources. Succession, inheritance, family governance, company ownership, trusts and estate planning vary by jurisdiction and family circumstances. Nothing on this page constitutes legal, tax, fiduciary, financial or investment advice.
WiT Access does not determine whether a particular succession, trust, family-governance or estate-planning structure is appropriate for your circumstances.
International succession planning may require coordinated advice from legal, tax, fiduciary and corporate professionals in several jurisdictions.