CBI Succession Planning 2026: Trusts, Inheritance and Family Strategy with a Second Citizenship

CBI succession planning means structuring a second citizenship so it protects the family across generations: including every eligible dependant in the original application (Antigua and Barbuda covers any family size for a USD 230,000 contribution), arranging citizenship for later-born children, choosing which law governs your estate, and holding assets in trusts or companies that work under modern tax transparency rules.

Families rarely buy a second citizenship for one person. The real question behind most enquiries we receive at Mirabello Consultancy is generational: will my children be covered, can my parents come too, what happens if I die, and how do I make sure the right people inherit? This guide answers those questions with figures taken from the official programme pages, and it is explicit about where the law ends and professional advice must begin.

What is CBI succession planning?

CBI succession planning is the coordinated planning of a family's citizenship, estate and asset structures after one member acquires a second nationality through citizenship by investment. CBI succession planning covers three layers: which relatives hold the new citizenship, which law governs the estate on death, and which entities (a trust, foundation or company) hold the assets that will pass to heirs.

Each layer has its own rulebook. Citizenship is governed by the nationality law and programme regulations of the issuing state. Succession is governed by the private international law of the countries where you live and own property. Tax is governed by residence and asset location. A good plan aligns all three, because a mismatch between them is where families lose time, money and certainty.

Can your whole family be included in one citizenship by investment application?

Your spouse and dependent children can be included in one citizenship by investment application in every Caribbean programme and in Vanuatu, and most programmes also accept dependent parents. The contribution often covers a family of four: St Kitts and Nevis charges USD 250,000 and St Lucia USD 240,000 for the main applicant plus three dependants.

The detail matters for succession, because each programme defines a dependant differently. St Kitts and Nevis accepts children under 18, children aged 18-30 in full-time education and fully supported, and parents of the applicant or spouse aged 55 or over who live with and are supported by the applicant. Dominica accepts children aged 18-30 in higher education, and parents or grandparents above the age of 65. Grenada is the programme that formally prices siblings, at USD 75,000 each on top of the National Transformation Fund contribution.

Due diligence and government fees are charged on top of these contributions. For a full side-by-side of costs, see our comparison of all five Caribbean programmes and the citizenship by investment hub.

What is Antigua and Barbuda citizenship by investment?

Antigua and Barbuda citizenship by investment grants citizenship for a USD 230,000 contribution to the National Development Fund, with the same contribution for a single applicant or a large family; the difference lies in processing fees. Antigua and Barbuda is therefore often the most cost-effective choice for families of five or more. Read the full Antigua and Barbuda programme guide.

What is St Kitts and Nevis citizenship by investment?

St Kitts and Nevis citizenship by investment is the longest-running Caribbean programme, granting citizenship for a USD 250,000 Sustainable Island State Contribution covering up to four family members. St Kitts and Nevis passport holders reach 157 destinations without a visa in advance, the highest count among the five. See the St Kitts and Nevis programme page.

What are Dominica, Grenada, St Lucia and Vanuatu citizenship by investment?

Dominica citizenship by investment starts from USD 200,000 for a single applicant through the Economic Diversification Fund. Grenada citizenship by investment starts from USD 235,000 for a family of four and is the only programme here with a published sibling price. St Lucia citizenship by investment starts from USD 240,000 including three dependants. Vanuatu citizenship by investment starts from USD 130,000 and is typically processed in 45-60 days. Programme guides: Dominica, Grenada, St Lucia and Vanuatu.

What happens to children born after you become a citizen?

Children born after you become a citizen by investment do not join automatically: each programme has a procedure to add a newborn or later child, normally through the citizenship unit, with a government fee and fresh due diligence on the parent. Timing changes the cost, and a child born while the application is still pending is usually the simplest case to add.

St Kitts and Nevis publishes the most detailed rules. Its citizenship unit distinguishes between a child born before the parent became a citizen, a child born while the application was pending, and a child born after citizenship, with different fees, routes and processing times for each. Spouses married after citizenship follow a separate, stricter route, and some places of birth are excluded from it. Other programmes handle later additions through their own fee schedules, so the answer for your family depends on the country and the child's age.

Separately from the investment programme, most Caribbean states also recognise citizenship by descent for a child born abroad to a citizen parent, which is a registration process rather than a new investment. St Kitts and Nevis and Grenada both have descent routes, explained on our St Kitts and Nevis citizenship by descent and Grenada citizenship by descent pages. Whether descent or a programme addition is the better route for a particular child is a question to settle before the child turns 18, when the adult rates apply.

Does a second citizenship change which law governs your estate?

A second citizenship can change which law governs your estate if you live in the European Union: under EU Regulation 650/2012, your succession is governed by the law of your last habitual residence, unless you choose in your will the law of a nationality you hold. A Caribbean nationality therefore opens a legal choice that did not exist before.

The European e-Justice Portal summarises the rule: the law of the Member State of last habitual residence applies by default, but citizens can choose the law of their country of nationality instead. The EU Succession Regulation (650/2012) applies to the estate as a whole, and in case C-21/22 (12 October 2023) the Court of Justice confirmed that a person living in a Member State may choose the law of a non-EU state of nationality. Denmark and Ireland do not apply the Regulation.

Why would a family make that choice? The five Caribbean states follow the common-law tradition of testamentary freedom: there is no fixed reserved share for children, although dependants can ask a court for reasonable provision. Several EU states, by contrast, reserve part of the estate for children under forced-heirship rules. Choosing a common-law nationality can therefore give a testator more freedom to provide for a spouse, a business successor or a family structure.

Three limits keep this honest. First, the choice must be made expressly, normally in a will, and it only works for a nationality you actually hold. Second, it does not touch tax: the Regulation excludes inheritance tax entirely. Third, some states protect reserved heirs regardless: France, for example, gives children a compensation right over French assets when the chosen foreign law has no reserved share. Our interactive guide, which law governs your estate, explains these rules country by country.

Do Caribbean CBI countries charge inheritance tax?

None of the five Caribbean citizenship by investment countries (Antigua and Barbuda, St Kitts and Nevis, Dominica, Grenada and St Lucia) or Vanuatu levies an inheritance or estate tax, according to their national revenue rules. Inheritance tax exposure, however, follows where you are tax resident, where the assets sit and, in some countries, where your heirs live, not your passport.

This is the single most misunderstood point in the market. Acquiring citizenship does not, by itself, make you tax resident anywhere. If you remain resident in Germany, the United Kingdom or Spain, your estate and your heirs remain within those countries' inheritance tax rules, and property you own there is taxed there regardless of your nationality. The absence of inheritance tax in the Caribbean matters mainly for assets located there and for families who genuinely relocate. We explain residence rules in depth in our guide to tax residence versus citizenship, and departure rules in exit tax planning with a second passport.

Summary for orientation only. Local rules on property transfer duties, stamp duty and probate still apply to assets located in each country, and a qualified tax adviser in your country of residence should confirm your own position.

Planning for several generations at once? Mirabello Consultancy works alongside your lawyers and tax advisers to align the citizenship file with your estate plan from day one. Book a complimentary consultation to map the right programme to your family.

What is a trust, and how does it work alongside a second citizenship?

A trust is a legal arrangement in which a settlor transfers assets to a trustee, who holds and manages them for named beneficiaries under the terms of a trust deed. A trust works alongside a second citizenship as the vehicle that holds family wealth, while the citizenship governs mobility and, in some cases, the choice of succession law.

The two solve different problems. A passport does not hold assets, and a trust does not grant residence or travel rights. Used together, they let a family decide in advance who controls the wealth, who benefits from it, and what happens if a beneficiary is a minor, falls ill or divorces. A foundation, available in several Caribbean and European jurisdictions, does similar work through an entity with its own legal personality, which some civil-law families find more familiar than a trust.

Nevis is the best-known Caribbean trust jurisdiction. Its international exempt trust and multiform foundation legislation is supervised by the Nevis Financial Services Regulatory Commission, and it includes provisions that refuse to recognise certain foreign judgments against a properly established trust. St Lucia and Antigua and Barbuda also have international trust or foundation legislation. These protections work only for structures set up in good faith, well before any claim arises, and with genuine trustee control. A trust created to defeat existing creditors or a pending divorce claim invites challenge in any jurisdiction.

You do not need to be a citizen of Nevis to use a Nevis trust, and holding St Kitts and Nevis citizenship does not make a Nevis trust more effective. The value of combining them is practical: one advisory team, one legal tradition, and a family that can travel to meet its trustees.

How does the Common Reporting Standard affect family trusts and accounts?

The Common Reporting Standard (CRS) requires banks and many trusts in participating countries to identify the tax residence of account holders and controlling persons, and to report balances and income to those residence countries. Under the Common Reporting Standard, a family trust reports its settlor, trustees, protectors and beneficiaries, so confidentiality from tax authorities is not available.

All five Caribbean CBI states and Vanuatu participate in automatic exchange of information. Banks also ask for your residence address and every citizenship you hold, and they are trained to question an account holder who declares residence in a no-tax jurisdiction without evidence of living there. The OECD guidance on residence and citizenship by investment specifically warns financial institutions about this risk. For families, the practical rule is simple: declare your real tax residence, keep evidence of it, and design the structure on the assumption that every element will be reported. Our guide to banking with a Caribbean passport covers account opening in detail.

Should family assets sit in a company, a trust or a foundation?

Family assets usually sit best in a combination: a company (often an international business company) to run an operating business or hold investments, and a trust or foundation above it to own the shares and decide who benefits. A company manages assets during life, while a trust or foundation governs succession and continuity after death.

A company alone does not solve succession: its shares are part of your estate and pass under your will or the applicable intestacy rules, possibly through probate in several countries. Placing the shares in a trust or foundation during your lifetime lets ownership continue without probate and gives the trustee or foundation council clear instructions. The trade-off is cost, governance and reporting, which should be proportionate to the wealth involved. For the company layer, see our Caribbean IBC company formation guide.

Simple estates often need neither. A family whose wealth is a home, investment accounts and a modest portfolio may be best served by coordinated wills in each country where assets sit, clear beneficiary designations and a properly drafted choice of law. Complexity should be earned, not assumed.

Which CBI programme suits multi-generational family planning?

The best CBI programme for multi-generational family planning depends on the family's shape: Antigua and Barbuda suits large families because its USD 230,000 contribution does not rise with family size, St Kitts and Nevis suits families including parents aged 55 or over, and Grenada suits families who want to include adult siblings.

Other factors follow from the family profile. Dominica, from USD 200,000 for a single applicant and USD 250,000 with up to three dependants, is a cost-effective choice for a couple with one or two children. Grenada also has an E-2 treaty investor agreement with the United States, although since 23 December 2022 a citizen who acquired Grenadian nationality by investment must first complete 3 years' continuous domicile in Grenada before applying, a timing point some business-owning families weigh when planning the next generation's careers. Vanuatu, from USD 130,000 with processing typically in 45-60 days, suits families who value speed. Mobility differs too: St Kitts and Nevis reaches 157 destinations without a prior visa, Antigua and Barbuda 154, Grenada 147, Dominica 145, St Lucia 144 and Vanuatu 90.

For a ranked view of all options, see the best citizenship by investment programmes in 2026.

What obligations keep a family's citizenship in good standing?

Keeping a family's citizenship in good standing means meeting each country's current national rules, renewing passports on time and keeping records up to date: Antigua and Barbuda requires 5 days in the country within the first 5 years, and St Kitts and Nevis requires citizens by investment to complete biometric enrolment.

St Kitts and Nevis launched national biometric enrolment on 14 April 2026, and existing citizens by investment must enrol by 31 July 2027. Grenada, Dominica and St Lucia have no presence requirement in force. A regional regulator, the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA), was established in December 2025 with its office in Grenada, but ECCIRA is not yet operating; the Eastern Caribbean Central Bank expects it to begin operating later in 2026, with no start date announced. Proposals discussed at regional level, such as 30 days of presence in the first 5 years, are not in force. Our country-by-country guide to the rules in force and ECCIRA explainer track these changes.

Children's passports expire sooner than adults' in many countries and must be renewed through the issuing state's own channels. Build renewal dates into the family calendar; our CBI passport renewal guide explains the process for each programme.

How do you build a family succession plan around a second citizenship?

A family succession plan around a second citizenship is built in six steps: map the family and its assets, choose the programme that fits the family's shape, include every eligible dependant in the first application, align wills and choice of law, decide whether a trust or company layer is justified, and review the plan every few years.

1. Map the family and the assets. List every relative you may want to include, with ages, and every asset with its location. Age thresholds (16, 18, 25, 30, 55, 65) change eligibility and fees.
2. Choose the programme for the family, not just the applicant. Compare total family cost, dependant definitions and later-addition rules, not only the headline contribution.
3. Include eligible dependants at the start. Adding relatives later generally means separate fees and a fresh due diligence review.
4. Align wills and choice of law. Consider a will in each country where you hold real estate, and, if you live in the EU, decide expressly whether to choose the law of a nationality you hold.
5. Add structures only where they earn their place. A trust, foundation or company should solve a defined problem: a minor heir, a business successor, assets in several countries.
6. Review regularly. Marriages, births, moves and law changes all affect the plan. A three-year review cycle is a sensible minimum.

Common mistakes in CBI succession planning

The most common mistakes in CBI succession planning are assuming a passport changes tax residence, leaving out relatives who would have qualified in the first application, relying on a single will for assets in several countries, and creating a trust too late or without genuine trustee control.

• Treating citizenship as a tax plan. It is not one. Residence and asset location decide tax.
• Letting a child age out. A dependant who passes an age threshold before submission may need to apply at the adult rate or separately.
• Forgetting matrimonial property. In many countries the marital estate is divided before succession law even applies, under separate rules.
• Relying on outdated information. Contribution levels, dependant rules and presence requirements have all changed in the last two years; always check the official programme page.
• Working with unlicensed intermediaries. Applications must go through government-authorised agents; see our guide to due diligence and licensed agents.

Official sources used in this guide: Antigua and Barbuda Citizenship by Investment Unit, St Kitts and Nevis Citizenship by Investment Unit, Dominica Citizenship by Investment Unit, Investment Migration Agency Grenada, St Lucia Citizenship by Investment Unit and Vanuatu Citizenship Office. This guide is general information, not legal or tax advice.