Portability of a policy from France to Portugal
24.03.2022
Depending on the country of residence, on which parts of the policy should a wealth transfer strategy be based?
Reading time: < 7 min
| France | Luxembourg | United Kingdom | Belgium | Germany | Portugal | |
| Disposition of the policy in a will | x | |||||
| Assignment of the rights under the policy and change of policyholer | X | X Gift of part of the policy, or of the policy itself, is possible |
X | X | X | |
| Assignment of the contractual position | X | |||||
| Assignment during his lifetime or post-mortem assignment | X | X | X | |||
| Nomination of beneficiaries in the beneficiary clause of the policy | X | X | X Implementation of a beneficiary clause in the case of a policy drawn up under civil law[2] |
X | X | X |
| Great flexibility in the drafting of the beneficiary clause. | X Dismembered beneficiary clause Beneficiary clause with options Beneficiary clause with charges … |
X | X[2] | X Dismembered beneficiary clause |
X | X |
| Possible joint subscription | X | X | X | X | X | X |
| Possible dismembered subscription | X | X | X | X | ||
| Possible nomination of several insured persons, and settlement on the death of the last insured, in order to delay transfer | 2 insured persons maximum[1] | 2 insured persons maximum[1] | 6 insured persons maximum[3] | 2 insured persons maximum | 2 insured persons maximum | 2 insured persons maximum |
[1] If the matrimonial regime of the co-subscribers so permits
[2] For a person living in the UK who is not a British national (e.g. a French national who is Non Deemed Domiciled in the UK), the ability to choose the law of their nationality
[3] If the policy is drawn up under UK law, the insured persons must represent an insurable interest for the policyholder (i.e. he himself or, in principle, his spouse)
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