As offshore investing becomes increasingly accessible to South Africans, cross-border estate planning is emerging as an important consideration beyond simply diversifying portfolios and accessing global markets.
Source: Supplied. Mariska Redelinghuys is the legal specialist advisor at PSG Wealth.
With more individuals holding assets outside the country, investors need to consider how their offshore wealth will be administered, protected and transferred to future generations. The implications extend beyond investment performance, encompassing inheritance rules, tax obligations and the legal requirements of different jurisdictions.
Whether investing through offshore funds, global share portfolios or other structures, having an appropriate estate plan in place can help avoid unnecessary costs, delays and complications for beneficiaries.
Preserving wealth and building a legacy: When viewed through an estate planning lens, offshore assets are more than simply investments. They form part of a family’s long-term wealth planning and may ultimately represent the assets that future generations inherit. The true success of an offshore investment should therefore be measured not only by its investment performance, but also by how effectively it can be transferred to beneficiaries.
For this reason, investment planning and estate planning should not be considered in isolation. Decisions made when establishing an offshore portfolio can have significant consequences, not only for the investor, but also for their heirs and beneficiaries.
Including offshore assets in your estate plan: A common misconception is that offshore assets do not form part of the normal estate-planning process. In reality, they are subject to many of the same estate-planning considerations as South African assets.
Just as investors consider the estate-planning implications of local investments, they should also evaluate how offshore assets will be administered, transferred and inherited after death. Without proper planning, beneficiaries may face delays, additional costs or unexpected legal complications.
Estate-planning outcomes often depend on both the nature of the offshore investments and the jurisdictions in which they are held.
How different offshore investments are treated during estate planning: Different offshore investment structures may result in different estate-planning outcomes.
Offshore endowments or sinking funds are often used as estate-planning tools because they allow investors to nominate beneficiaries who can elect to either continue with the investment themselves or to receive its proceeds. This can provide greater certainty about where the proceeds will go and may simplify the administration process after the death of the investor.
Sanisha Packirisamy 6 Nov 2026 For investors focused on efficient wealth transfer and succession planning, this can be an important consideration when selecting an offshore investment structure.
Global share portfolios and global investment funds are generally treated differently to offshore endowments or sinking funds. These investments will typically form part of a deceased investor’s estate and are ordinarily distributed according to the provisions of the investor's will or the succession laws of the relevant jurisdiction.
Investors should therefore ensure that their wills are properly drafted and reviewed regularly to adequately address their offshore holdings where necessary.
Offshore jurisdictions
The estate-planning implications of offshore assets are not determined solely by the investment product. The jurisdiction in which an asset is situated can be equally important.
Different countries apply different succession rules. Some impose forms of forced heirship, requiring certain assets to pass to specific family members regardless of the provisions of a will. Others provide greater testamentary freedom, allowing individuals more flexibility when determining how their assets should be distributed. Understanding the succession laws that apply to an offshore asset is therefore an essential part of cross-border estate planning.
Tax treatment can also differ significantly from one jurisdiction to another. Depending on where assets are located, an investor's estate may be exposed to inheritance taxes or other death-related taxes and costs in addition to those applicable in South Africa.
These expenses can reduce the value ultimately received by beneficiaries and should be carefully considered when structuring offshore investments.
Where investors hold assets across multiple jurisdictions, the interaction between local and foreign tax systems can become increasingly complex. Specialist advice can help to identify potential risks and opportunities before they arise.
