Czech Beneficiaries of UK Pensions: Take Action Before 2027

by | Jan 14, 2026

What are the issues for beneficiaries in the Czech Republic of inheriting a UK pension?

If someone living in the UK leaves a pension to family members in the Czech Republic, it’s natural to assume that having a Czech will is enough. After all, if the will is valid where the beneficiaries live, surely that should cover everything.

Unfortunately, when it comes to UK pensions and UK inheritance rules — especially after 2027 — a Czech will on its own often creates more problems than it solves.

Why This Question Matters More After 2027

From April 2027, most unused UK pension funds will be included in the deceased’s estate for UK inheritance tax purposes. That means:

  • Pension benefits become part of the probate process.
  • Executors must report them to HMRC.
  • Inheritance Tax may need to be paid before funds are released.

So pensions are no longer “outside the estate” in a simple way. They become formal UK estate assets. This brings UK courts, UK tax law, and UK pension providers firmly into the process — even if all beneficiaries live abroad.

A Czech will does not automatically solve the problem of inheriting a UK pension. It may be legally valid, but it is procedurally inefficient for UK assets.

A small amount of preparation can prevent a great deal of frustration later.

Chris Lean

Chief Investment Officer, Aisa International CZ

Why a Czech Will Is Not Enough

A UK pension is governed by UK law, not Czech law. UK pension providers and HMRC need authority under UK legal procedures before they can act. A Czech will does not automatically give anyone that authority in the UK.

So even with a Czech will, someone must still:

  • Obtain UK probate (or have the Czech probate decision formally recognised in the UK),
  • Show HMRC that tax has been dealt with,
  • And satisfy the pension provider’s compliance requirements.

That takes time, money, and paperwork.

Foreign Wills Create Extra Steps

If there is only a Czech will, the executor usually has to:

  • Translate and legally certify the will,
  • Apply to have it recognised or “resealed” in the UK,
  • Possibly instruct UK solicitors to navigate the UK probate system.

Each of these steps adds delay and cost — and none of them increase what beneficiaries receive.

Pension Providers Are Cautious

UK pension providers are heavily regulated and extremely risk-averse- particularly post Brexit for any matter outside of the UK. Faced with foreign documents and foreign court orders, they typically take a conservative approach: no payment until everything is confirmed under UK rules.

This often means months of waiting while paperwork moves between countries.

What This Means for Beneficiaries

From the beneficiary’s perspective, relying only on a Czech will can result in:

  • Long delays before money is released,
  • Higher legal and administrative fees,
  • Confusion about who is responsible for dealing with HMRC,
  • Stressful cross-border bureaucracy at a difficult time.

None of this is fatal — but all of it is avoidable.

The Better Solution

The simplest approach is usually:

  • A Czech will covering Czech assets, and
  • A separate UK will covering UK assets (especially pensions).

And, written so that the two wills do not conflict or cancel each other.

This structure:

  • Speeds up probate,
  • Reduces costs,
  • Makes life much easier for executors and beneficiaries,
  • And significantly reduces the risk of delays or disputes.
Summary

A Czech will does not automatically solve the problem of inheriting a UK pension. It may be legally valid, but it is procedurally inefficient for UK assets.

After 2027, when pensions become fully integrated into the UK inheritance tax and probate system, relying only on a Czech will is likely to cause delays, extra expense, and unnecessary complexity for those left behind. If a UK pension is meant to support someone in the Czech Republic, cross-border planning matters — and a small amount of preparation can prevent a great deal of frustration later.

The views expressed in this article are not to be construed as personal advice. Therefore, you should contact a qualified, and ideally, regulated adviser in order to obtain up-to-date personal advice with regard to your own personal circumstances. Consequently, if you do not, then you are acting under your own authority and deemed “execution only”. The author does not accept any liability for people acting without personalised advice, who base a decision on views expressed in this generic article. Importantly, where this article is dated then it is based on legislation as of the date. Legislation changes but articles are rarely updated, although sometimes a new article is written; so, please check for later articles or changes in legislation on official government websites, as this article should not be relied on in isolation.

Vyjádřené názory v tomto článku nelze považovat za osobní poradenství. Vždy se proto obraťte na kvalifikovaného, ideálně regulovaného poradce, který vám poskytne aktuální, osobní doporučení šitá na míru vaší konkrétní situaci. Pokud se rozhodnete jednat bez takového poradenství, činíte tak na vlastní odpovědnost a vaše jednání spadá pod režim „execution only“ (pouhá realizace pokynu bez poradenství). Autor nepřijímá žádnou odpovědnost za rozhodnutí osob, které se spoléhají na názory uvedené v tomto obecném článku bez personalizovaného poradenství. Je důležité si uvědomit, že pokud je článek datován, vychází z právních předpisů platných k uvedenému datu. Právní předpisy se mohou měnit a články jsou aktualizovány jen zřídka. Doporučujeme proto vždy ověřit případné novější články nebo změny legislativy na oficiálních vládních stránkách, protože na tento článek nelze spoléhat izolovaně.

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Autorem článku je:

Chris Lean

In the UK he worked with accountants as an independent financial adviser, qualified as a Chartered Financial Planner and became an examiner for the Chartered Insurance Institute. He also qualified as a European Financial Planner and specializes in investment and pension advice to clients.

Aisa International is the only financial advice service company specialising in advice for expats that is regulated as a Securities Trader in the Czech Republic, USA, and UK.