Category: PPLI by Country

South Africa: Estate Duty, the Named Beneficiary Rule and Life Insurance

South Africa’s estate duty framework has a clean structural parallel with the UK’s inheritance tax problem: a life insurance policy paid to the deceased’s estate is included in the dutiable estate; a policy paid directly to a named beneficiary is generally excluded. The solution is structural — not a trust, but a beneficiary designation. South African trust law is mature and well-developed, adding a further planning layer for UHNWI clients. GLOBAL ESTATE PLANNING SERIES Overview — The Global LandscapePart 2 — EU Civil Law: France, Germany, Spain and BelgiumPart 3 — The UAE and GCC: Succession Without Estate TaxPart 4 — Japan and Asia: The World’s Highest Inheritance Tax RatePart 5 — The United States: Estate Tax, the ILIT, and

The United States: Estate Tax, the ILIT, and Where PPLI Fits

The US federal estate tax applies at 40% on the taxable estate above the applicable exemption — currently at historically high levels but subject to a scheduled reduction. Life insurance owned by the deceased is included in the taxable estate unless held in an Irrevocable Life Insurance Trust. PPLI, as KPMG has noted, is “a potential option to increase one’s after-tax investment returns while providing for transition of assets upon death.” The US is the most sophisticated market globally for the intersection of PPLI and estate planning. GLOBAL ESTATE PLANNING SERIES Overview — The Global LandscapePart 2 — EU Civil Law: France, Germany, Spain and BelgiumPart 3 — The UAE and GCC: Succession Without Estate TaxPart 4 — Japan and

Japan and Asia: The World’s Highest Inheritance Tax Rate and the Life Insurance Exemption

Japan’s 55% maximum inheritance tax rate is the highest in the developed world. The Japanese legislature built a specific life insurance exemption into the Inheritance Tax Act — ¥5 million per statutory heir — as a deliberate policy tool. For UHNWI clients with Japanese connections, life insurance is not peripheral to estate planning. It is central to it. GLOBAL ESTATE PLANNING SERIESOverview — The Global LandscapePart 2 — EU Civil Law: France, Germany, Spain and BelgiumPart 3 — The UAE and GCC: Succession Without Estate TaxPart 4 — Japan and Asia: The World’s Highest Inheritance Tax Rate (You are here)Part 5 — The United States: Estate Tax, the ILIT, and Where PPLI FitsPart 6 — South Africa: Estate Duty and

The UAE and GCC: Life Insurance, Sharia Succession and the Forced Heirship Problem

The UAE imposes no inheritance tax, no estate duty, and no capital gains tax on death. The estate planning problem in the Gulf is not tax — it is who receives the assets. For the approximately 88.5% of the UAE population who are non-citizen expatriates, and for Muslim citizens subject to Sharia succession rules, life insurance is one of the most powerful tools available. Getting the structure right requires understanding what Sharia inheritance law actually mandates, and how DIFC, ADGM, and offshore structures interact with it. GLOBAL ESTATE PLANNING SERIESOverview — The Global LandscapePart 2 — EU Civil Law: France, Germany, Spain and BelgiumPart 3 — The UAE and GCC: Succession Without Estate Tax (You are here)Part 4 — Japan

EU Civil Law and Life Insurance: When a Trust Is Not the Answer

In the UK, a trust removes a life insurance policy from the estate and eliminates its Inheritance Tax exposure. In France, Germany, Spain, and Belgium — the four largest continental European UHNWI markets — the trust either does not exist in local law or is explicitly ignored for tax purposes. This piece examines what that means in practice and what tools actually work in each jurisdiction. GLOBAL ESTATE PLANNING SERIESOverview — The Global LandscapePart 2 — EU Civil Law: France, Germany, Spain and Belgium (You are here)Part 3 — The UAE and GCC: Succession Without Estate TaxPart 4 — Japan and Asia: The World’s Highest Inheritance Tax RatePart 5 — The United States: Estate Tax, the ILIT, and Where PPLI

Life Insurance and Inheritance Tax: The Global Landscape

The UK series on this blog established how a trust structure removes a life insurance policy from an estate and neutralises its inheritance tax exposure. That analysis is country-specific. Across 44 jurisdictions tracked by EY’s Worldwide Estate and Inheritance Tax Guide, the problem — and the solution — looks markedly different. This piece maps the global landscape and introduces the dedicated country series that follows. GLOBAL ESTATE PLANNING SERIESOverview — The Global Landscape (You are here)Part 2 — EU Civil Law: France, Germany, Spain and BelgiumPart 3 — The UAE and GCC: Succession Without Estate TaxPart 4 — Japan and Asia: The World’s Highest Inheritance Tax RatePart 5 — The United States: Estate Tax, the ILIT, and Where PPLI FitsPart

You’re Not Moving to Greece Yet – But Your Money Might Want To

For non-residents with Greek assets, the tax picture is manageable. For those considering relocation, the opportunity is exceptional — and structuring decisions made now determine the outcome. You own a property in Crete. Or you hold shares in a Greek company your family started twenty years ago. Or you are watching the Golden Visa programme and calculating whether Athens, Thessaloniki, or one of the islands might eventually suit a relocation. You are not a Greek tax resident. Not yet. But you have Greek assets. And those assets create Greek tax exposure that most non-resident owners manage imperfectly — and that PPLI can help address, both now and in the context of any future move. This article is for non-residents with

Greece Has a €100,000 Tax Cap on Everything Your Portfolio Earns. Here’s What That Means for PPLI

How Article 5A’s non-dom flat tax, combined with PPLI, creates the EU’s most efficient structure for inbound residents — and why Greece now outperforms Italy, Spain, and France for large portfolios. Imagine telling a client: no matter how much your investment portfolio earns this year — whether it is €200,000 or €2 million — your Greek income tax on those gains is the same fixed number. €100,000. Paid once. Done. That is not a hypothetical. It is Article 5A of the Greek Income Tax Code, introduced by Law 4646/2019, and it is currently the most powerful single provision in European tax law for high-net-worth individuals with offshore investment portfolios. When you combine it with Private Placement Life Insurance, the result

PPLI for Non-Residents with Italian Assets: What It Can and Cannot Do

Advisers sometimes present offshore Private Placement Life Insurance to non-resident clients holding Italian assets as if the wrapper eliminates the Italian tax problem. It does not. Italian-source income and gains are taxable in Italy regardless of whether those assets sit inside a PPLI or outside it. The wrapper addresses the tax position in the client’s country of residence. It does not override Italian source-country taxation. That qualification matters a great deal, and it needs to be stated at the outset. What PPLI can do for non-residents with Italian assets is still significant — but advisers who start with an accurate picture of the limits will build better structures and avoid disappointed clients. The fundamental distinction Italy taxes non-residents only on

PPLI for Italian Tax Residents: What You Need to Know

Italy is not an obvious PPLI jurisdiction. It has a stamp duty on foreign financial assets, a mandatory foreign-asset declaration regime, and a tax authority that has spent the last decade tightening enforcement on offshore structures. For a standard Italian tax resident, the case for offshore Private Placement Life Insurance is real but qualified. For a new Italian tax resident who has elected the flat tax regime under Article 24-bis of the Italian Tax Consolidated Act, the case is fundamentally different. Italy’s New Tax Resident regime — doubled from EUR 100,000 to EUR 200,000 per year by Law 143 of October 2024 — makes Italy one of the most structurally efficient jurisdictions in Europe for large PPLI portfolios. Understanding the difference between these two

Category: PPLI by Country

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