Relocation
You are not choosing a country. You are choosing a legal system — and from the day you move you have two.
Every spreadsheet put in front of me has columns for tax rate, cost of living, weather and years to a passport. None has ever had the column that decides the outcome: what the move itself costs — and what Iranian nationality does to you in the destination. This page answers the second question, country by country.
This page is orientation, not legal advice — neither on the immigration nor the tax law of any destination. Which visa, which route and which tax consequence: that is assessed solely by professionals admitted there.
What is here — and what is not
So that nobody leaves with the wrong expectation, the limit comes first.
The demarcation Law of the destination
I do not assess visa categories, residence titles, naturalisations or tax consequences in the destination. Those questions belong to the lawyers, migration agents and tax professionals admitted there — instructed separately, answering for their own advice. In Canada and Australia, immigration advice is itself a licensed activity.
Why the page exists anyway. Because between all those advisers lies a layer none of them covers: what your Iranian nationality, your Iranian documents and the assets you left in Iran trigger in the destination. That layer regularly decides whether the others’ plan works at all — and it is almost always noticed too late.
Four questions that precede every move
These four apply to all eight countries. They are almost never asked in this order — and that is exactly where most plans fail.
- A visa is not a tax status. Legal residence and tax residence are two systems with two different tests. The title says where you may live; days present and the centre of your life say where you are taxed. Whoever treats them as one discovers a year later that two states claim them.
- The country you leave sends an invoice. Departure is often the largest single item in the whole project and almost always the last discovered. You budget for the destination; the origin bills you first. Whether and how much is for the tax professional of the state of departure to tell you — not me.
- The regime you are moving for may not outlive the move. Special regimes for newcomers are regularly amended, time-limited or closed. A plan resting on a single incentive has exactly the lifespan of that incentive. The current position is checked by the professional on the ground, shortly before the step — not by an article from the year before last.
- Every destination asks for your money’s biography. Plans rarely fail at the immigration authority. They fail at the bank. Before the account opens comes the question where the capital came from and whether it can be evidenced in that institution’s language. A clean file in one system is worth nothing if it does not meet the standard of the other.
- What you leave behind does not stay behind. The flat in Tehran, the share in the Iranian company, the estate never formally divided — none of it ends at the airport. It has to be documented while you still have access; not three years and three time zones later, through relatives.
Eight countries — for whom, and what to settle first
What is assessed here is solely the Iranian dimension: what your nationality, your documents and your assets in Iran trigger in each system. Tax rates, visa routes and cost of living are deliberately absent — the professionals on the ground exist for that.
Germany
Country pageFits above all
Anyone who wants their estate to continue following Iranian law. For Iranian nationals the 1929 treaty designates Iranian succession law — regardless of which residence title you hold and how long you have been here.
What comes with you
The passport decides; residence is irrelevant. Two consequences: your mahr from an Iranian marriage deed is a quantified claim here, not a symbol — and naturalisation is a succession cut-off date, from which German succession law applies and every earlier plan belongs under review.
To settle before the flight
A power of attorney with the right scope for everything that continues in Iran; certified civil status and marriage documents; the registry position of the assets left in Iran, recorded while you still have access.
USA
Country pageFits above all
Anyone who inherited assets in Iran or owned them before becoming a US person. For exactly that constellation there is the general licence 31 CFR § 560.543: sale in Iran and transfer of the proceeds — subject to conditions. Property received as a gift only after becoming a US person generally falls outside it.
What comes with you
US-person status begins long before the passport — at the green card, and for acts from within the US at mere presence (31 CFR § 560.314). From that day every Iran-related transaction runs through the sanctions regime. And leaving the system later is expensive and formal; that is assessed by US tax and sanctions counsel, not by me.
To settle before the flight
Close the documentary chain for Iranian assets before the change of status: determination of heirs, registry evidence, tax clearance. After the switch, every step in Iran becomes a sanctions question — which US counsel must then answer before anything happens.
United Arab Emirates
Country pageFits above all
Anyone who orders their succession before arriving. For Iranians the Emirati basic rule points to Iranian succession law — but only on application and against proof. Whoever has not prepared the proof gets the local distribution.
What comes with you
The visa — employment, investor, golden visa — does not change the succession statute; it changes where your assets sit. And there they are frozen from the day of death: accounts, joint accounts included, shareholdings, dealings in real property. Release comes only after the court establishes the heirs.
To settle before the flight
The succession arrangement under local law, with the Iranian evidence obtained in advance, translated into Arabic and legalised; the heirs’ powers of attorney; and a clear allocation of accounts. After the day of death nobody negotiates — only the file counts.
France
Country pageFits above all
Anyone who wants to choose Iranian succession law. France sits under the EU Succession Regulation: the default is habitual residence, but Art. 22 EuErbVO permits a testamentary choice of the law of nationality. That door is shut in Germany — here it is the central planning tool.
What comes with you
The French counterweight: Art. 913(3) Code civil gives each child a compensating claim over the French-situs estate where the applicable foreign law knows no reserve mechanism protecting children. Whether Iranian law contains such a mechanism is a question of Iranian law — and must be answered to the notaire in writing.
To settle before the flight
If the choice of law is wanted: make the will in good time and in valid form — not once the case has already arisen. Alongside it, the Iranian documents with the legalisation chain and, for the notaire, the certificat de coutume.
England and Wales
Country pageFits above all
Anyone with a closed documentary position. Iranian law is a question of fact here and must be proved by expert evidence; where nobody does so, the court may presume it matches English law (Brownlie [2021] UKSC 45). Whoever has their Iranian papers in order has the advantage — whoever does not loses the presumption against themselves.
What comes with you
A particular pitfall: a marriage concluded only religiously and not effectively registered may, from the English standpoint, be no marriage at all — with the consequence that the financial claims of a divorce fall away. The marriage registered in Iran is the opposite case; its proof from the Iranian registers opens what stays shut to the bare ceremony.
To settle before the flight
Certified extracts from the Iranian registers: marriage, divorce, civil status, land register — with translation. Iran is not a party to the Apostille Convention; the chain is longer than most people plan for.
Canada
Country pageFits above all
Anyone who can allow for time — and who grants their powers of attorney before leaving. Since the closure of the Iranian embassy in Ottawa in 2012, consular matters for Iranians in Canada run through the Iranian Interests Section in Washington. That lengthens every documentary chain by weeks.
What comes with you
Family, estate and commercial matters run under provincial law, and Iranian law comes in as expert evidence — unproven, it is treated like the forum’s own. Regularly, the question also arises whether Iran is genuinely available as an alternative forum.
To settle before the flight
A power of attorney with a sufficiently wide scope, granted while you can still reach an Iranian consulate without complication. Every correction costs the whole chain from the start here — and here it is longest.
Australia
Country pageFits above all
Anyone who knows what they actually hold in Iran — and can evidence it. Family matters run nationwide with full disclosure of worldwide assets. Whoever knows and has documented their Iranian position stands well; whoever estimates it does not.
What comes with you
Precisely what stays invisible from the Australian standpoint: unregistered purchase contracts, titles held through relatives, vaqf-bound values, shareholdings behind the gazette position. Invisible does not mean irrelevant — it only means someone has to make it visible.
To settle before the flight
An honest inventory of the Iranian assets with registry searches, before it is compelled in proceedings. What you disclose yourself is evidence; what the other side finds is an allegation.
Türkiye
Country pageFits above all
Anyone who needs the geographical proximity and can live with a split estate. Under Art. 20 MÖHUK succession is governed by the deceased’s national law — Turkish law applies only to immovables located in Türkiye. For Iranian families with property there that means: one estate, two legal systems.
What comes with you
The consular routes are short and well-worn — that is this destination’s practical advantage. But: foreigners do not obtain the certificate of inheritance from a notary; the route runs through the civil court of peace. Whoever does not know that loses weeks in the wrong queue.
To settle before the flight
Clarify the allocation before investing: what will land on the Turkish and what on the Iranian side of the estate — and whether the structure you are planning really wants that outcome.
What I contribute
The Iranian side of the move Iranian law
Source of funds for investor and entrepreneur routes: the money’s path from the Iranian source to the investment, documentarily closed — registered sale, determination of heirs, distribution resolution, tax file, each legalised and explained in writing. Alongside it the power of attorney with the right scope, the civil status and family documents every authority will demand, and the administration of what remains in Iran.
The right moment is beforehand. Almost everything on this page can be done in weeks with access to Iran, and in months without it — if at all. The most expensive version is always the one where, three years later, a relative tries to obtain a document whose exact name nobody remembers.
Limit. No advice on the immigration, migration or tax law of any destination, no sanctions determinations, no funds through me. If a person involved is on a sanctions list, the matter is not accepted.
Enquiries concerning a relocation
Outline the matter briefly by email and state what is to be achieved. You will receive an indication of which part falls to be settled under Iranian law and which part needs a professional admitted in the destination. Please do not send confidential documents in a first message.