Opinion article by Mariana Morais Teixeira | "International Inheritance Tax Law - Portuguese Perspective"

Mariana Morais Teixeira signs an opinion article entitled "International Inheritance Tax Law - Portuguese Perspective", recently published in the Revista Electrónica de Fiscalidade da Associação Fiscal Portuguesa.

«Due to globalisation, free movement of persons, enhanced by growing migratory movements and stimulated by national incentives to attract tax nomads, greater ease in acquiring property abroad, right of establishment and internationalisation of private investment, it is becoming increasingly frequent for an individual to be connected to various jurisdictions that are perpetuated and relevant after his death.

Take for instance a situation in which an individual dies and at that time he was habitually resident in State R, was a national of State N, held securities deposited with a bank in State B and real property in State I; his successors were resident in State S. The geographical spread of persons and assets, as illustrated in this example, has inheritance and tax repercussions, and raises challenges for beneficiaries of cross-border successions, among which the issue of international double taxation is relevant.

This study aims to understand the phenomenon of cross-border inheritance taxation and its impacts, and to point out the existing approaches to mitigate double taxation, analysing them comparatively and critically, with incursions into national and international doctrine and jurisprudence where relevant».

Click here to read the article.

[The opinions expressed in this article are binding only on the author].