Second citizenship, residence rights and investment assets do not all pass to family members in the same way after death. Citizenship by descent depends on the law of the country concerned, residence permits are generally personal to the holder, and property passes under the relevant succession rules.

A second passport also does not, by itself, remove UK Inheritance Tax exposure. Since 6 April 2025, the treatment of overseas assets for UK IHT purposes is principally linked to long-term UK residence rather than domicile.

What passes and what does not

Asset or status	Can it pass?	Key point
Caribbean citizenship	Sometimes by descent or registration	Rules differ by country and family circumstances
Citizenship for a later spouse	Not automatically	Registration or another application may be available
Malta MPRP status	Not automatically	Agency has discretion in limited circumstances after a beneficiary’s death
Greek Golden Visa	Not inherited as an asset	Family members’ residence rights depend on immigration rules
Overseas property	Yes	Subject to succession, probate and tax rules
UK IHT exposure	Not changed by another passport alone	Long-term UK residence is central to foreign-asset exposure

Citizenship for children and later family members

Caribbean citizenship rules should be checked country by country rather than assuming citizenship only passes to children born after an investor was naturalised.

For example, Grenada’s Constitution provides that a person born outside Grenada is a citizen where a parent was a Grenadian citizen at the time of birth. Grenadian authorities also publish registration procedures for children of Grenadian parents, including adults, so an older child should not automatically be treated as permanently excluded.

St Kitts and Nevis also operates post-citizenship addition procedures. Its Citizenship Unit currently permits applications for certain spouses, children and parents added after the main applicant obtained citizenship, subject to eligibility rules and fees. Some dependants omitted from the original application may instead need to use another application route.

Our comparison of Caribbean citizenship options in 2026 and guide to second citizenship for children explain why family planning should form part of the original application.

What happens to residence rights?

Residence permits are not property that can simply be inherited.

Under Malta’s MPRP regulations, however, the position is more nuanced than an automatic cancellation for the whole family. Following the death of a beneficiary, the Residency Malta Agency may, in exceptional circumstances and at its discretion, issue a certificate to an approved dependant if the required conditions are met.

That makes family composition important when reviewing MPRP costs for families.

Greek Golden Visa residence is also tied to the qualifying investor and investment. Family members receive their own residence documentation, but their status is linked to the sponsor subject to the applicable rules. Property itself can pass through the estate, but inheriting it should not be assumed to give an heir an automatic Golden Visa. The heir’s immigration position must be assessed separately against the rules then in force.

See our renewals guide, golden visas for families and comparison of residency and citizenship by investment.

The UK inheritance tax position

From 6 April 2025, an individual is generally a long-term UK resident for IHT purposes after being UK tax resident for at least 10 of the previous 20 tax years. A person leaving the UK can remain within the long-term residence rules for between three and ten tax years, depending on their prior residence history.

The standard IHT nil-rate band remains £325,000, with a residence nil-rate band potentially available in qualifying circumstances. A 40% rate commonly applies to the taxable estate above available allowances and exemptions, but the final liability depends on the estate.

Holding another nationality does not alter this test. See the official HMRC guidance on inheritance tax and our guide to day counting and tax residency.

Cross-border wills also require care. Under the EU Succession Regulation, a person can generally choose the law of a country whose nationality they hold to govern their succession, including the law of a non-EU country. That choice should be clearly expressed in the will.

Our guide to buying Greek property as a UK resident covers related estate-planning considerations.

Frequently asked questions

Do I need a separate will for each country?

Not necessarily. Cross-border estates can sometimes be covered by coordinated wills, but they must be drafted carefully so that one does not accidentally revoke another.

Does my spouse automatically inherit my second citizenship?

No. Marriage does not automatically transfer citizenship. Depending on the country, a spouse may qualify for registration or another application route. See our guide to second passport practicalities.

Which route is best for multi-generational planning?

It depends on the family’s ages, nationalities and long-term objectives. Compare St Lucia citizenship by investment with residence options including the Italy investor visa, Hungary golden visa and Greek residence routes.

Before applying, consider who should be included now, who could qualify later and how your property and tax position would be handled on death. Speak to our citizenship and residency solicitors about planning the residence, citizenship and succession position together.