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The short answer
Often yes. The UK charges inheritance tax on worldwide assets, including Nigerian property, for people who were UK resident for at least 10 of the previous 20 tax years; others pay only on UK assets. The IRS counts everything a US citizen or resident owns at death in the gross estate, with a 2026 basic exclusion of $15 million. In Ireland, an inheritance is fully within CAT if the person who died or the heir is Irish resident. Nigeria itself has no inheritance tax.
A family house in Enugu or a plot in Abuja can feel like it belongs entirely to Nigeria. For inheritance tax, what usually matters is not where the property is but the residence or status of the person who dies, and in Ireland of the person who inherits.
Nigeria: no inheritance tax
Nigeria does not levy an inheritance or estate tax. Under the Nigeria Tax Act 2025, passing property on death is not a chargeable disposal, and heirs take the property at its market value at the date of death, which becomes their cost if they sell later (Bloomberg Tax, February 2026). Gifts in life are different: they are treated as disposals at market value. For what heirs face where they live, see inheriting from Nigeria.
United Kingdom: the long-term residence test
From 6 April 2025 the UK replaced domicile with a residence test. HMRC's manual (IHTM47020, April 2026) says foreign assets are within inheritance tax if the person was a long-term UK resident, meaning UK resident in at least 10 of the 20 tax years before the year of death. A split year counts as a full year. People who leave keep that status for a 'tail' of three to ten tax years, depending on how long they were resident, before foreign assets fall outside.
For someone who was not a long-term resident, only UK assets are in scope. GOV.UK gives the standard threshold is £325,000, with 40% above it; it can rise when a home passes to children or grandchildren, and transfers to a spouse are exempt.
Worked example
Example only, ignoring the residence nil-rate band and spouse exemption. A long-term UK resident dies with a London home and savings worth £400,000 and a Lagos house valued at £150,000.
| Without Lagos house | With Lagos house | |
|---|---|---|
| Estate | £400,000 | £550,000 |
| Less threshold | £325,000 | £325,000 |
| Taxable | £75,000 | £225,000 |
| Tax at 40% | £30,000 | £90,000 |
The Lagos house adds £60,000 of UK tax. Because Nigeria charges no inheritance tax, there is no Nigerian tax to set against it.
If you move back to Nigeria
Leaving the UK does not end exposure at once. IHTM47020 sets the tail: three tax years for someone resident for 10 to 13 years, one more year for each extra year of residence, up to a maximum of ten years for 20 years or more. HMRC's own example is a person resident for 15 years, whose tail is five years. A returnee who dies in Lagos within the tail can still owe UK inheritance tax on the Lagos house.
United States: the gross estate
The IRS estate tax FAQ (July 2026) defines the gross estate as everything a person owns or has certain interests in at death, including real estate, cash, securities and business interests, without carving out property abroad. The basic exclusion is $13,990,000 for 2025 and $15,000,000 for 2026. Form 706 is due nine months after death when the gross estate plus adjusted taxable gifts exceeds the threshold, or to elect portability of an unused exclusion to a surviving spouse. Most Nigerian families in the US fall well below the exclusion, but the portability election can still be worth filing.
Ireland: capital acquisitions tax
Ireland taxes the heir, not the estate. Revenue's notes on the CAT Act say the whole inheritance is taxable if the person who died was resident or ordinarily resident in Ireland, or the heir is resident or ordinarily resident at the date of the inheritance. A foreign-domiciled person is not treated as resident for this purpose unless resident for five consecutive tax years before. CAT is 33% above the heir's group threshold. For gifts or inheritances on or after 7 October 2026, the thresholds are €420,000 for children (Group A), €44,000 for siblings, nieces, nephews and parents in some cases (Group B) and €22,000 for others (Group C).
Valuing the Nigerian property
Each tax office wants a market value at the date of death in its own currency. Use a qualified, registered estate surveyor and valuer in Nigeria, and keep the report with the title documents. A valuation also fixes the heirs' cost for any later Nigerian gains tax.
What to check first
- Count your years of residence in the country you live in, and the tail if you move.
- Value your Nigerian property at a realistic market value; tax offices can challenge low values.
- Make sure your Nigerian title is clear so executors can deal with it; see selling Nigerian property from abroad for the sale side.
- Consider whether a will in each country is needed, and take legal advice on how they fit together.
Where Pryme fits
Executors often need to pay Nigerian costs in naira (valuers, lawyers, Land Use Charge) while the estate sits abroad. A Pryme account holds naira and your home currency together, with Send for paying in Nigeria and Swap when you choose to convert.
Questions people ask
Does UK inheritance tax apply to my house in Nigeria?
If you were UK resident for at least 10 of the 20 tax years before death, yes: foreign assets are in scope. If not, only UK assets are taxed.
Is there inheritance tax in Nigeria?
No. Under the Nigeria Tax Act 2025, inheritance is not a chargeable disposal; heirs take the property at market value at death.
I inherit my father's Lagos house and I live in Dublin. Do I pay CAT?
If you are Irish resident or ordinarily resident at the date of inheritance, the whole inheritance is within CAT, at 33% above your group threshold (€420,000 for a child from 7 October 2026).
Does the US count Nigerian property for estate tax?
The IRS defines the gross estate as everything owned at death, including real estate, without excluding property abroad. The 2026 basic exclusion is $15 million.
Sources
- HMRC IHTM47020: long-term residence test · accessed Oct 2026
- GOV.UK: Inheritance Tax · accessed Oct 2026
- IRS: Frequently asked questions on estate taxes · accessed Oct 2026
- Revenue: CAT group thresholds · accessed Oct 2026
- Revenue: Notes for guidance, CATCA 2003 Part 2 · accessed Oct 2026
- Bloomberg Tax: New Nigeria tax law redefines capital gains tax for individuals · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.