Cross-Border Succession: What Asia's Great Wealth Transfer Means for Vietnamese Founders
NAC Perspective · Vietnam · Wealth
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Cross-Border Succession: What Asia's Great Wealth Transfer Means for Vietnamese Founders

The great wealth transfer has begun. For Vietnamese founders whose children live abroad, succession now runs through several legal systems at once — plan it early.

The largest intergenerational wealth transfer in history is under way, and most first-generation Vietnamese founders will enter it with their assets in one country and their heirs in another. Succession then stops being governed by a single law: the owner's nationality, the location of each property and the children's country of residence can each bring their own rules. The safest approach is to plan residency, asset location and succession together, with licensed lawyers in every jurisdiction involved.

Most writing about the "great wealth transfer" is told from the vantage point of American or European families — households with several generations of accumulated capital, a toolkit of trusts, and legal systems long used to handling inheritance. The Vietnamese founding family sits somewhere quite different. Its wealth was usually built within a single generation, the founder often still runs the business, and the children are studying, working and starting families abroad.

That means "who inherits" is only half the question. The other half — "under which country's law, and through what procedure" — is one that very few families ask until it is too late.

The biggest wealth transfer in history, seen from Asia

According to the UBS Global Wealth Report 2025, published in June 2025, more than USD 83 trillion is expected to change hands over the next 20–25 years: about USD 74 trillion between generations and USD 9 trillion between spouses. Mainland China alone is projected to see more than USD 5 trillion pass between generations over the next two decades.

Asia's version of this story has a distinctive feature. The people handing over wealth are often still relatively young, and are frequently the same people who created it. The transfer here is therefore not only about dividing assets; it is also about handing over control of a business, its partnerships and the family's reputation.

A UBS survey of the next generation, reported by The Standard (Hong Kong) in May 2026, found that more than 40% of the Asia-Pacific families surveyed were in the process of transferring wealth or actively planning to do so. About 72% of heirs in the region turn to professionals first, compared with 42% in North America and 19% in Europe. The sample was small, so treat these figures as a directional signal rather than a firm conclusion — but the signal is clear: Asia's next generation wants guidance.

First-generation founders and heirs abroad

Concentrated assets, dispersed heirs: For many Vietnamese families, wealth sits mainly in Vietnam — in company shares, land and homes — while the children live in the United States, Australia, the UK or Europe. According to Open Doors 2025 data reported by the Vietnamese Government's news portal in November 2025, nearly 25,600 Vietnamese students were enrolled in the US in the 2024–2025 academic year, a record high that keeps Vietnam among the top five countries sending students there.

Studying today, settling tomorrow: Not every student stays, but many will work, marry and gradually build a life in their host country. A decade later, that heir may hold another nationality, be tax resident elsewhere, and carry obligations their parents in Vietnam have never had to consider.

A generational gap in how wealth is seen: Founders often see wealth as tied to place — a plot of land, a factory, the family home. Heirs raised across cultures tend to see it as a portfolio that can move. When these two views are never spoken aloud, succession easily becomes a source of family tension.

Every country, its own inheritance rules

Vietnam looks to nationality and to where property sits. Under Article 680 of the 2015 Civil Code, succession is governed by the law of the country of which the deceased was a national immediately before death, but the exercise of inheritance rights over real estate follows the law of the country where the property is located (Vietnam Lawyers Journal, 2021). In practice, an apartment in Athens or London goes through Greek or English procedures, even when its owner is a Vietnamese citizen.

A will does not always have the last word. Article 644 of the same Code gives minor children, parents, spouses and adult children unable to work at least two-thirds of their statutory share, even if the will leaves them nothing (Vietnam Lawyers Journal, 2021). Many countries have similar protections, but they differ in who is protected and by how much.

The European Union looks to habitual residence. Under EU Succession Regulation 650/2012, which applies to deaths from 17 August 2015, the default law for the whole estate is that of the country where the deceased was habitually resident at death; Denmark and Ireland do not take part (Mondaq, 2016). The regulation also lets a person choose the law of their nationality instead. When Vietnam looks to nationality and the EU looks to residence, the two systems can point to different laws for the same family.

Tax is a separate story. In the UK, the standard inheritance tax rate is 40% on the value above the £325,000 threshold (GOV.UK). Since 6 April 2025, whether overseas assets fall within UK inheritance tax depends on "long-term UK residence" — being UK tax resident for at least 10 of the previous 20 years — and that status can last for up to 10 tax years after leaving (GOV.UK, 2025). A son or daughter who has lived in London for more than a decade can therefore bring even assets inherited from Vietnam into the UK's tax net.

In the United States, the federal estate tax exemption for citizens and residents is USD 15 million per person from 2026 (Morgan Lewis, October 2025). For someone who is neither a US citizen nor a US resident, however, the executor must file an estate tax return once US-situated assets — such as US real estate or shares in US companies — exceed USD 60,000 (IRS). The gap between those two thresholds is enormous, and it is often overlooked.

Vietnam, by contrast, has no standalone inheritance tax. The 2025 Personal Income Tax Law, in force from 1 July 2026, continues to exempt income from inheriting real estate between spouses, between parents and children, and among certain other close relatives (VietNamNet, January 2026). That comfort at home can make families complacent about obligations abroad.

Why residency, asset location and succession belong in one plan

An heir's nationality can change what they can own. According to an analysis by Tuoi Tre (August 2023, based on the 2013 Land Law), heirs holding only a foreign nationality could not be registered as holders of land-use rights in Vietnam; they could transfer or gift those rights, or receive their value. The 2024 Land Law is now in force, so the details must be confirmed by a lawyer under current rules — but the principle stands: a child's naturalisation abroad is a variable in the succession plan, not only in the migration plan.

Parents' residence is a variable too. A founder who retires and spends most of the year in Europe may, over time, become habitually resident there. The law governing the estate — and the tax — can shift with them, even though they never intended to "move" any assets.

Asset location dictates procedure. Property in a given country goes through that country's process. Each process means a period when the asset may be frozen, and a legal bill. So a new apartment abroad should be weighed not only for its yield but also for how it will eventually pass on.

These three variables — who lives where, where the assets sit, and who will receive them — interact. Planning each in isolation tends to produce outcomes nobody in the family actually wants.

The role of lawyers and professional advisers

No single document can handle inheritance in every country. Each legal system has its own requirements for the form of a will, notarisation, legalisation and the procedure for confirming heirs. A family with assets or heirs in several countries needs a lawyer licensed in each relevant jurisdiction, and a tax adviser who understands both sides.

This article is not legal or tax advice. Its purpose is to help families ask the right questions before they sit down with a lawyer, because a productive consultation starts with a clear picture of the assets, nationalities and residences of every family member.

A practical strategy for Vietnamese investors

Map the family before you map the assets. Write down each family member's nationality, tax residence and likely plans for the next ten years — then place the assets on that map. Most cross-border succession risks surface at this step.

Choose where new assets sit with two questions in mind: yield and transfer. Before buying property abroad — a London apartment such as Bermondsey Place, for example — ask a lawyer which law will govern its inheritance, how it will be taxed and how long the process is likely to take.

Plan residency for the whole family, not just one person. A residency that covers spouses and children, such as the Greece Golden Visa programme, can help a family keep its options open within the same legal area. But residency can also bring tax obligations, so it should be reviewed alongside the succession plan.

Review regularly, especially after major events. A child's marriage or naturalisation, a parent's retirement, or a change in the law are all reasons to reopen the file. A plan drawn up in 2026 may no longer fit in 2030.

Frequently asked questions

If my child has taken a foreign nationality, can they still inherit my assets in Vietnam?

Their right to the value of the estate is generally preserved, but their right to hold land in Vietnam in their own name may be restricted if they no longer hold Vietnamese nationality. Ask a Vietnamese lawyer how the 2024 Land Law applies before changing any ownership structure.

Is a will made in Vietnam enough for assets abroad?

Often not. Property abroad passes through the procedures of the country where it sits, each with its own requirements on form and recognition. Many families need additional wills or documents that fit local law, drafted together so they do not contradict one another.

Vietnam has no inheritance tax, so do I need to worry about tax at all?

Yes, if assets or heirs are in another country. Countries such as the UK and the US can tax based on where assets sit or where the people involved live, and the amounts can be significant. An international tax adviser should look at both sides.

NAC strategic insight

The great wealth transfer is not a distant concern for Western dynasties. For the first generation of Vietnamese founders whose children are growing up abroad, it is starting this decade. The families who handle it best will treat residency, asset location and succession as one plan — and start while everyone still has time to talk it through.

NAC does not replace your lawyers. Our role is to help families see the residency and overseas-asset part of that picture clearly, then connect them with licensed lawyers and tax advisers in each country. If your children are studying or working abroad, book a consultation with NAC and start with the family map.

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