Inheritance between Spain and the UK: who taxes what

Spain and the UK tax inheritances in opposite ways. The UK charges inheritance tax on the estate of the person who has died. Spain charges inheritance and gift tax to each person who receives something. There is no inheritance tax treaty between the two countries, so the same assets can be taxed in both.

The UK side

Since April 2025 the UK looks at residence rather than domicile. Someone who has been UK resident for ten of the last twenty tax years is taxed on their worldwide estate; others pay only on UK assets, such as a flat in London.

The Spanish side

Heirs resident in Spain pay on everything they receive, wherever it is. Heirs living abroad pay only on assets in Spain. The rate depends on the region, and some regions reduce the bill for close family to very little; heirs living outside Spain can usually apply those regional rules too.

When both apply

Spain allows a credit for tax paid abroad on the same assets, up to the Spanish tax on them. Timing matters: the UK bill is usually settled before the estate is shared out, and the Spanish return is due six months after the death.

We map who lives where, what is held in each country and which rules apply, and agree the wills and gifts that make sense in both systems.