High-Net-Worth Retirement Planning: A Global Guide for the US, UK and Spain

For High-Net-Worth Individuals, retirement planning requires more than standard advice, especially when navigating the conflicting tax regimes of the US, UK, and Spain.

This global guide explores the “Tri-Jurisdiction Challenge,” offering essential strategies to mitigate double taxation, manage currency volatility, and navigate estate laws.

Discover how to structure your assets efficiently to protect your legacy across borders.

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Table of Contents

Introduction

Planning your retirement when you’re a high-net-worth individual (HNWI) is far more than simply setting up a pension fund.

With complex assets, multiple residencies, and differing tax regimes across the US, UK, and Spain, effective high-net-worth retirement planning demands strategic coordination, not chance.

At Private Client Consultancy, we specialise in guiding affluent clients through every stage of this complex journey, helping you protect, grow, and enjoy your wealth wherever life takes you.

What You Will Learn

For HNWIs with international lifestyles, traditional “domestic” advice often falls short. What works for a retiree in London rarely suits one splitting time between Miami and Marbella. In this guide, we cover:

  • The Tri-Jurisdiction Challenge: Why the US, UK, and Spain tax systems often clash.

  • Key Definitions: A glossary of essential terms like QROPS, SIPP, and the Solidarity Tax.

  • The 6 Stages of Planning: A step-by-step approach to high-net-worth retirement planning.

  • Real-World Strategy: How a coordinated approach can mitigate double taxation.

The Tri-Jurisdiction Challenge: Why Standard Plans Fail

Affluent individuals face challenges beyond simply saving a nest egg. Your wealth often spans multiple asset classes, currencies, and jurisdictions, each with distinct legal and tax systems.

This is why specialised high-net-worth retirement planning is essential; without a cohesive cross-border strategy, you risk:

  1. Double Taxation: The US taxes based on citizenship, while Spain and the UK tax based on residency. Without careful planning, and correct application of Double Taxation Treaties, you may pay tax on the same income twice.

  2. Estate Tax Traps: While the US has a high estate tax exemption ($13.61m in 2025), Spain has no estate tax treaty with the US. This exposes US citizens in Spain to significant Inheritance Tax (IHT) risks. [read more about Spanish IHT here]

  3. Currency Volatility: If your income is in Sterling or Dollars but you spend in Euros, market fluctuations can erode your purchasing power overnight. [link to Horizon]

  4. Asset Fragmentation: Owning real estate and businesses across borders complicates reporting and liquidity.
Spain is unique in Europe for applying a Wealth Tax (Impuesto sobre el Patrimonio). While regions like Madrid and Andalusia offer 100% relief, the national "Solidarity Tax" on net wealth over €3 million can still apply, overriding regional exemptions.

HNWI Glossary: Defining the Tools

To navigate international retirement, you must understand the vehicles available to you.

 

 

  • Spanish Compliant Investment Bonds: Tax-efficient life assurance policies designed for Spanish residents, allowing for tax deferral on growth.

 

The Six Stages of High-Net-Worth Retirement Planning

Step 1: Define Your Retirement Vision

Start by defining what your retirement looks like, location, lifestyle, legacy goals, and level of financial independence.

Clarity at this stage ensures your wealth is structured to support your desired lifestyle, not the other way around.

Step 2: Audit Your Global Wealth

Catalogue your assets, liabilities, income sources, and pensions across jurisdictions. This includes investment accounts, trusts, real estate, business equity, and offshore holdings.

If you are Moving from the USA, ensure you review your 401k and IRA positions before becoming a Spanish tax resident to avoid punitive taxation on withdrawals.

Step 3: Structure for Tax Efficiency

Select the right mix of vehicles based on residency and treaty alignment.

  • For UK Pensions: With the abolition of the Lifetime Allowance (LTA) in April 2024, the focus has shifted to the new “Lump Sum Allowance” (£268,275). High earners must navigate these caps carefully. Pension Planning services can help determine if a QROPS or staying in a SIPP is more beneficial.

 

  • For US Exposure: US citizens must navigate “PFIC” rules which punish holding non-US mutual funds. A tailored portfolio is essential.

Step 4: Design a Sustainable Investment and Drawdown Strategy

Your wealth must support decades of retirement. Adopt multi-currency investment portfolios and Euro-denominated drawdown structures to protect purchasing power.

Solution: Balance growth with capital preservation. High-net-worth retirement planning must consider drawdown timing to reduce tax drag and sequence-of-returns risk, specifically aligning with Spain’s savings tax rates (ranging from 19% to 28%).

Step 5: Estate and Succession Planning

For HNWIs, retirement planning overlaps with legacy design.

  • Forced Heirship: Unlike the UK and US, Spain has “forced heirship” rules that dictate how assets are distributed to children.

 

  • IHT Liability: Coordinate wills and trusts across jurisdictions. UK domiciles are liable for UK IHT on worldwide assets, while Spanish residents face regional succession taxes. Our Inheritance Tax Planning services ensure these liabilities do not erode your legacy.

Step 6: Governance and Ongoing Review

Tax laws (like the recent UK Budget changes or Spain’s Solidarity Tax) evolve. Regularly review your plan to ensure compliance, efficiency, and alignment with your long-term goals.

Case Study: A Transatlantic Retirement Strategy

The Scenario: Michael and Laura, dual citizens of the UK and US, split their time between London and Mallorca. Their wealth includes UK pensions, US investment accounts, and Spanish property.

The Problem: They faced UK income tax on pension drawdowns, US tax on their global income (citizenship-based), and potential Spanish Wealth Tax on their global assets.

The PCC Solution: Private Client Consultancy Wealth Management created a coordinated plan:

  1. Pension Consolidation: Utilised a QROPS to consolidate UK pensions, removing them from the UK tax net.

  2. Currency Hedging: Created a US-compliant investment portfolio in USD and EUR to match their spending needs.

  3. Legacy Structuring: Implemented a cross-border estate structure that utilised the Brussels IV regulation to bypass Spanish forced heirship rules.

 

The Result: This structure reduced their projected Inheritance Tax exposure by 22%, provided stable Euro income, and simplified their annual reporting to the IRS and Hacienda.

Frequently Asked Questions

Can I retire in Spain with a US 401k?

Yes, but it is complex.

Spain generally taxes foreign pension income as general income (up to 47%+), and the US does not have a treaty protecting the tax-deferred status of a 401k in the same way it does with other nations.

Proper timing of withdrawals is critical.

No.

The Double Taxation Treaty covers Income and Capital Gains, but it does not explicitly exempt you from Spain’s Wealth Tax.

However, taxes paid in the US or UK may sometimes be offset against Spanish liabilities depending on the specific asset class.

As of April 2024, the Lifetime Allowance was replaced. You can now generally take up to £268,275 tax-free. Any lump sums above this may be taxed at your marginal rate.

Final Thoughts: Make Your Wealth Work Internationally

Your wealth should enable freedom, not create complexity.

With professional guidance, high-net-worth retirement planning can deliver tax efficiency, currency stability, and intergenerational continuity across borders.

At Private Client Consultancy Wealth Management, we help clients in the US, UK, and Spain create global retirement strategies that protect their wealth and legacy, for life and beyond.

Ready to Plan Your Global Retirement?

Book a complimentary consultation today and discover how to structure your retirement plan for maximum efficiency, flexibility, and peace of mind.

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We’ve Moved Offices on 1st August 2025!

Private Client Consultancy is excited to announce that we have moved to a brand-new office space, designed to better serve our clients and reflect our continued growth.

Effective Date: Friday, 1st August 2025
New Address: Urb Jazmin De Miraflores, C. Jazmín, 2, Mijas Costa 29649, Malaga, Spain
Our phone numbers and email addresses remain unchanged.

All in-person meetings scheduled from 1st August onwards will take place at our new location. Please update your records accordingly.

We look forward to welcoming you to our new space!

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