How the map gets drawn by accident

A career spanning Almaty, Baku, Tbilisi, Tashkent, Dubai and a European posting tends to leave a trail: a local salary account in each country, a brokerage opened while resident somewhere else, a Swiss vested-benefits account left behind, an apartment bought where a family member lives, and an insurance policy sold in a market you no longer live in. Individually each was reasonable. Collectively they are rarely coherent — and no single adviser sees all of it.

The remedy is unglamorous. Build one list: institution, country, account type, currency, ownership, approximate value, who has access, and what documentation exists. Most people find at least one item they had not thought about in years, and at least one where the paperwork would not survive a serious event.

Assume the position is visible

Cross-border financial accounts are, in most cases, no longer private from tax authorities. Under the OECD Common Reporting Standard, participating jurisdictions exchange financial account information automatically with the account holder's jurisdiction of tax residence, and a large number of countries — including many in the region and in the Gulf — participate. Practical consequences follow: a structure that only works if it is not reported is not a structure, and information you have not declared may already have been shared.

Where you are tax resident is therefore a foundational fact, not a formality. Domestic definitions differ, dual residence is possible, and where a treaty applies its tie-breaker rules may resolve the conflict. Each country's tax authority is the primary source, and residence should be confirmed for each year in question, not assumed.

Succession is the harder problem

Tax mistakes cost money; succession mistakes cost time, access and family peace. Different countries apply different rules to the estates of foreigners, including forced-heirship provisions and separate treatment of immovable property, which is very often governed by the law of the country where it is located regardless of any will.

Within the EU, the EU Succession Regulation determines which law applies to a cross-border succession and permits a choice of the law of nationality in defined circumstances — relevant if any part of your family or property sits inside the EU. Outside that framework, national conflict-of-law rules apply. The practical tests are simple to state: does a valid will exist in each country where assets are held; do those wills contradict one another; can your executors identify and reach the assets; and are beneficiary designations on pensions and policies consistent with the wills? Swiss occupational and pillar 3a arrangements, for example, follow a statutory beneficiary order that a foreign will does not override.

Access, custody and continuity

Consider what happens if you cannot act. Which accounts require in-person attendance in a specific city? Which have no valid power of attorney? Which are tied to an email address or telephone number you would lose on changing country? Where are original documents held, and can your family reach them? Consolidating accounts is not always desirable, but reducing the number of institutions that require your physical presence usually is.

Custody quality matters as much as location. Regulatory regime, investor-protection arrangements, segregation of client assets and the ability to serve a client resident in your country all vary, and some institutions restrict or close accounts for residents of particular jurisdictions. Ask, in writing, whether a provider will continue to serve you at your new address before you rely on it.

Currency, and what you measure in

Assets in several countries usually mean liabilities in several currencies. Decide which currency you measure success in — normally the one your long-term liabilities are denominated in — and view the rest as exposure to be matched or diversified deliberately. Our note on regional currency volatility sets out that framework in more detail.

Turning the inventory into a plan

Once the list exists, three passes are usually enough. First, close or consolidate what is redundant, dormant or unreachable. Second, correct anything inconsistent: beneficiary nominations, wills, addresses of record, powers of attorney and reporting. Third, decide what each remaining pot is actually for, in which currency, and on which horizon. Our six-point cross-border review works well as the checklist for that exercise.

Cross-border structuring depends on residence, nationality, domicile and the law of each jurisdiction concerned. Obtain tax and legal advice in every relevant country before restructuring; nothing here is advice on your circumstances.

A better next step

Before acting, bring the pension, tax and investment decisions into one cross-border review. Hansa Perpetual can help structure the questions and coordinate the planning process with appropriately qualified tax and legal specialists where required.