The two systems in one view
The UK taxes the estate — 40% above the thresholds, with worldwide scope tracking long-term residence under the current framework. The Netherlands taxes the receiver — rates rising with distance from the deceased and per-heir exemptions doing real work for spouses and children. Same family, two philosophies.
The treaty and the ten-year shadow
The UK–Netherlands inheritance treaty of 1979 assigns taxing rights and prevents double charges where both systems reach. Movers should also know the Dutch ten-year rule: Dutch nationals remain in Dutch inheritance scope for a decade after emigrating — relevant for Dutch-passport family members, and a reason cross-border estates get mapped early.
Structure beats improvisation
The Dutch toolkit plans succession while everyone is alive: the certification foundation moves value to children while steering stays put (the STAK), the family foundation encodes the charter (the constitutional layer), and the holding keeps business wealth in corporate solution where lifetime planning has room: the family-office frame.
The one-afternoon exercise
List the assets by country, mark each with the system that reaches it, and let the treaty map show where planning pays — then structure the big items deliberately. Estates handled this way turn a two-system problem into a filing exercise: where it fits in the move.