From the UK & Europe

Inheritance Planning Between the UK and the Netherlands

Updated: 6 October 2026 Holdwise editorial team Inheritance UK Planning

Families with ties to both the UK and the Netherlands deal with two very different inheritance tax systems. The UK taxes the estate at 40%, based on residence. The Netherlands has progressive rates that depend on the relationship with the deceased. The overlap is settled by a special inheritance tax treaty between the two countries. With a good structure, you need the treaty less often. At Holdwise, we keep this answer up to date. You find the steps further down this page.

The two systems compared

The UK taxes the estate at 40% above the thresholds. Under the current rules, this applies to assets worldwide if the deceased was a long-term UK resident. The Netherlands taxes the person who receives the inheritance. The more distant the relationship with the deceased, the higher the rate. For spouses and children, the exemption per heir is important. One family may have to deal with both systems at the same time.

The treaty and the ten-year rule

Under the inheritance tax treaty of 1979 between the UK and the Netherlands, each country has defined taxing rights. Where both systems apply, you pay tax only once. If you relocate, you should also know the Dutch ten-year rule. Dutch nationals stay subject to Dutch inheritance tax for ten years after they emigrate. This is important for family members with a Dutch passport. For this reason, map a cross-border estate early.

Planning with Dutch structures

With Dutch structures, you plan the succession while everyone is alive. With a certification foundation, you transfer value to your children and keep control separate (see the STAK). In a family foundation, you set out the family rules (see the governance guide). In a holding company, you keep business wealth in a corporate structure, where you have room for planning during your lifetime. See the family-office guide.

Is your group setting up a Dutch entity? See setting up a Dutch subsidiary for what you need, how long it takes and what the parent company must sign.

In the Netherlands, a family office has three parts: a holding company, a foundation that issues depositary receipts (STAK) and a foundation for giving. Families organise the decisions in three ways. Read more on a family office in the Netherlands.

Map your assets in one afternoon

List the assets by country, mark each with the system that applies to it, and use the treaty to see where planning pays off. Then structure the big items with care. Estates handled this way turn a two-system problem into a filing exercise: where it matches in the relocation.

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Part of Doing Business in the Netherlands, the complete 2026 guide.

Frequently asked questions

Does relocating to the Netherlands end UK inheritance exposure? +

It is a gradual change that takes time: the UK’s residence-based rules keep long-term leavers in scope for a period after they leave. Planning before the relocation should note the exact dates that matter for your file.

How generous are Dutch spouse and child exemptions? +

Very generous. The partner exemption is one of the largest in Europe. Each child has a smaller exemption of its own, €26,230 in 2026, and the rates for partners and children (10% and 20%) are far below the UK rate of 40%. Dutch rates are higher for more distant relatives.

Can gifts during your lifetime help with both systems? +

Yes, often. In both systems, you pay less tax if you give early and document your gifts. In the Netherlands, you can also use structures such as the certification of shares. Giving on a regular schedule is one of the most effective parts of the plan.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 6 October 2026