Citizenship is not inherited like a house or a bank balance. It passes by birth, descent or registration under the nationality law of the country that granted it. Caribbean citizenship by investment can usually be passed to children, but rules for grandchildren and later generations vary by country. Greek and Portuguese residence permits do not pass to heirs at all. The property or fund units behind them pass under local succession law, and UK inheritance tax can still apply to your estate wherever your passport comes from.

This article separates those three things, because families regularly confuse them when planning.

What you hold	Does it pass to your children?	What governs it
Caribbean citizenship	Usually yes for children, but later generations depend on the country	The country’s nationality law
Greek or Portuguese residence permit	No, it is personal to the holder	Immigration rules
Property or fund units	Yes, as part of your estate	Local succession law and tax
UK inheritance tax exposure	Stays with your estate	UK residence history and asset location

Can citizenship be passed down to your children?

Yes, in most Caribbean citizenship by investment programmes, but the detail matters. Children included in your original application receive citizenship alongside you. Children born afterwards may acquire citizenship by descent, registration or a post-citizenship addition process, depending on the country. Rules for grandchildren and later generations differ, so check the nationality law in force when each child is born.

In practice, three situations come up. Children already in your family when you apply can often be included as dependants, usually up to around age 30 if they are unmarried and financially dependent, although age and dependency tests vary. Children born after you become a citizen may have a route to citizenship, but it may require registration and fees. Adult children or other relatives added later usually need a separate process with its own eligibility checks. Our guide on what your family actually inherits from a second passport sets out how these routes differ by country.

The programmes are not identical. Dominica is commonly marketed as a citizenship that can pass to future generations, but registration rules and fees still matter. St Lucia’s citizenship by investment programme also allows citizenship by descent or registration in defined circumstances, but later-generation claims can be more technical. St Kitts and Nevis has also been updating descent rules, so do not assume a marketing phrase gives the full answer. Where sources disagree, treat the statute and official process in force at the date of birth as the answer, not a brochure. Our Dominica programme guide covers family inclusion in detail, and St Kitts and Nevis citizenship by investment has its own post-citizenship process for adding family.

We often see families assume that applying later costs the same as applying early. It rarely does. Including children in the original application is usually simpler and cheaper than registering them afterwards, a point we also make in our piece on education and succession planning for mobile families.

Why a Caribbean passport does not remove UK inheritance tax

Caribbean programmes often have no local inheritance tax, which is real but easy to misread. If you are UK resident, the UK decides whether your estate is taxed, not the country on your second passport.

Since 6 April 2025, the UK inheritance tax test for foreign assets has moved from domicile to long-term residence. You are a long-term UK resident if you have been UK tax resident for at least 10 of the previous 20 tax years, and your worldwide assets, including overseas property, can then fall within UK inheritance tax. You can stay in scope for up to 10 tax years after leaving the UK, with a shorter tail where your UK residence history was shorter, as HMRC’s long-term resident guidance on GOV.UK explains.

The standard rate is 40% on the part of an estate above the £325,000 nil-rate band, and gifts made within seven years of death can be pulled back in, according to the GOV.UK inheritance tax overview. The available threshold can rise where the residence nil-rate band applies, for example where a qualifying home passes to direct descendants. A Golden Visa or a second passport changes none of this on its own.

Do residence permits pass to heirs?

No. A residence permit is personal to the person who holds it. Your children inherit the asset behind it, not the permit.

Greece. The Golden Visa is tied to a qualifying investment, often a property that meets the relevant value, size and location rules. Family members hold dependent permits that rely on the investor staying compliant. Greece’s 2026 circular for investors adds one useful rule. If the investor dies and the surviving spouse acquires the whole property, the spouse can convert from family member status to an investor permit based on that same property. Our breakdown of the circular covers the detail.

An adult child who inherits the property does not automatically step into your permit. They may be able to apply in their own right if the inherited property still meets the programme tests and they clear due diligence. If they do not need a permit, they can usually sell without migration consequences, subject to normal costs. Our guide to Greece Golden Visa requirements lists the tests an heir would need to satisfy.

Portugal. The permit again belongs to you, and your investment normally needs to stay in place while the residence permit depends on it. Our exit strategy guide explains what happens when you sell or redeem.

Citizenship is the harder question. Under the May 2026 nationality law changes, most non-EU investors now face a 10-year legal residence period before naturalisation, and the calculation should be checked against the law and procedure in force when the application is made. Children who hold dependant permits follow their own qualifying position. A child born in Portugal does not automatically become Portuguese through a Golden Visa alone. Under the 2026 rules, at least one parent normally needs to have held legal residence for five years, with further conditions applying. Our summary of the route to Portuguese citizenship explains how this affects family timelines.

How property and investments pass on, and what they cost

The asset side is more straightforward than the immigration side, but the tax treatment still needs planning.

Country	Who is taxed on inheritance	Rate for children and spouses	Rate for other heirs
Greece	Anyone inheriting Greek real estate, whatever their nationality	Banded rates for close relatives, commonly up to 10% after allowances	Higher bands for more distant relatives and unrelated heirs
Portugal	Portuguese-situated assets passing by gift or inheritance	Spouses, descendants and ascendants are generally exempt from the 10% stamp duty charge	Usually 10% stamp duty, with property-related stamp duty points needing local advice

Greek real estate is taxed on succession even if the owner never lived there, so a UK family holding a Golden Visa flat should expect Greek paperwork alongside any UK filing. Our guide to managing a Greek purchase from abroad is useful here, because the Power of Attorney and tax number set up at purchase often matter again at succession.

Portugal abolished a classic inheritance tax in 2004 and uses stamp duty instead. Spouses, descendants and ascendants are generally exempt from the 10% charge, but other heirs such as siblings or friends are not. Lifetime gifts and property transfers can raise additional stamp duty questions, so the exact route matters. Where Greek or Portuguese tax is paid, double tax relief or treaty credit may reduce the UK bill on the same asset, though higher-rate UK estates can still owe a top-up.

Practical steps before you need them

A few habits prevent most of the problems we see.

1. Make a will in each country where you own property, or confirm that your UK will is recognised there.

2. Consider choosing your nationality’s law to govern your estate. The EU succession regulation allows this, and for a British national that normally means English law, although local formalities, forced-heirship limits in some situations and tax still need local advice.

3. Keep original certificates, apostilles and translations for every family member, since heirs and dependants are asked for them years later.

4. Check hold periods before any gift or sale, particularly on citizenship-linked property, where our note on the St Kitts and Nevis genuine link reforms shows how fast the rules can move.

5. Use a lawyer rather than a consultant for cross-border succession, as we explain in our comparison of lawyers and consultants.

It also helps to understand what a Golden Visa solicitor actually does before you instruct one, since estate planning is often outside a standard immigration brief.

If a second passport for your children is the real goal

If your main aim is to give children options rather than hold European property, the programme choice changes. The difference between residency by investment and citizenship by investment matters here, because only citizenship creates nationality rights for the next generation. Even then, “hereditary” does not mean the same thing in every country. Our guide to choosing a Caribbean citizenship in 2026 compares family inclusion across the islands, and the due diligence checks explain what each adult applicant will face.

For European residency without a property, the Greece Financially Independent Person visa and Italy’s investor visa are worth comparing, though neither creates a passport for your children. Families with older children may also find our piece on parents of university bound children and our overview of the best Golden Visa options in Europe helpful.

Frequently asked questions

Can my grandchildren inherit my Caribbean citizenship?

Sometimes, but it depends on the country and on whether the relevant parent was born a citizen, naturalised, or registered later. Some Caribbean programmes are marketed as passing citizenship to future generations, but later-generation claims can involve technical rules and registration steps. Confirm the specific nationality rule before relying on it.

Can my children inherit my Golden Visa?

No. Residence permits are personal and cannot be inherited. Your children inherit the property, fund units or other investment, and may be able to apply for their own permit if that asset still meets the programme rules.

Does a second passport reduce UK inheritance tax?

No. UK inheritance tax follows your UK residence history and the location of your assets, not simply your nationality. Long-term UK residents can be taxed on worldwide assets at 40% above the available thresholds.

Can a child born in Portugal or Greece claim citizenship automatically?

Not through a Golden Visa alone. Portugal now requires parental legal residence and further conditions for children born in Portugal to foreign parents. Greece does not grant citizenship simply because a child was born there to investor parents.

Do I need a separate will in each country?

Often yes, or at least confirmation that your existing will is valid and practical locally. A short local will for each property can save months of delay, provided it is coordinated with your main estate plan.

If you want to protect your children’s position, whether through a second passport, a European permit or the property behind it, Coates Global’s immigration lawyers can map your options against your family and your estate. Get in touch before you apply, since adding children later is rarely as simple or as cheap as including them at the start.