In most Common Law jurisdictions estate planning may include the use of Trusts.
However, in most European countries the legal system governing estate planning is very different, and will most probably include ‘forced heirship’ laws and the imposition of succession or gift taxes (which are paid by the beneficiaries, the settlor or even both).
Some countries would not recognize the legal system of Trusts and did not enter into “The Hague Trust Convention” – an international agreement on the Law Applicable to Trusts and on their Recognition. The use of Foundations (Stiftungen) is more common.
In such cases, all Trusts Assets are deemed to be personal assets of the Settlor if it comes to Wealth Tax.