- United Kingdom: The United Kingdom largely follows Western norms for wealth transfer, using legal instruments such as wills and trusts to determine the division of assets upon an individual’s death. Solicitors play a critical role in crafting these documents to ensure they are legally binding and represent the individual’s wishes accurately. While the cultural norm is to divide assets equally among children, the person drafting the will has complete discretion to divide their estate as they see fit. The UK also imposes an inheritance tax on estates that exceed a certain threshold, which can significantly impact the amount of wealth transferred. It’s worth noting that over the past few decades, more people have been considering leaving a portion of their estate to charitable causes. This reflects the growing influence of American-style philanthropy in the country.
- China: Wealth transfer in China is heavily influenced by Confucianism, a philosophy that prioritises familial obligations and respect for elders. Traditionally, the eldest son was considered the primary heir, receiving the lion’s share of the family wealth. However, modernisation and the influence of communism have disrupted this norm, with a growing trend towards equal distribution among all children. Despite this shift, there is still a strong emphasis on filial piety, with children, especially sons, expected to financially support their parents in their old age. In urban areas, this may involve transferring property to parents to ensure they have a place to live. Conversely, in rural areas, parents may transfer land and property to their sons on the condition they will be cared for in their old age.
- India: In India, wealth transfer is a complex process influenced by a range of factors, including regional customs, religious laws, and secular laws. Among Hindus, the traditional expectation was that the family’s wealth would remain undivided and pass on to the eldest son, who would then assume responsibility for his parents and unmarried sisters. However, the Hindu Succession Act has led to a shift towards more equal distribution among all children. Meanwhile, Muslim families in India typically follow Islamic laws of inheritance, which dictate the specific shares each family member is entitled to, with sons usually receiving twice the share of daughters.
- Middle Eastern Countries: Many Middle Eastern countries follow Islamic inheritance laws, also known as Sharia law. Under Sharia law, wealth transfer is a highly regulated process, with set proportions allocated to different heirs. Generally, male heirs receive twice the share of female heirs, reflecting their traditional role as providers. However, before any wealth is distributed to the heirs, debts must be paid off, and a portion of the estate may be donated to charity as part of ‘Zakat’, one of the Five Pillars of Islam. This demonstrates the important role philanthropy plays in Islamic wealth transfer practices.
- United States: The United States follows a Western model similar to the UK, with individuals drafting wills to specify how their assets should be divided. While there is a common trend towards equal distribution among children, there is also a significant emphasis on philanthropy in the US, more so than in many other cultures. Wealthy individuals often establish charitable foundations, endow university chairs, or donate substantial sums to causes they care about. This philanthropic streak reflects the American ideals of individualism and giving back to society.
- African Cultures: Africa is incredibly diverse, with different countries and ethnic groups each having their unique norms regarding wealth transfer. In many traditional African societies, wealth, especially land, is often held communally rather than individually. This means that the transfer of wealth isn’t a simple process of passing assets from parents to children but involves a complex system of communal rights and responsibilities. For example, among the Akan people of Ghana, a matrilineal system of inheritance is followed, meaning wealth is transferred through the female line. In other societies, the eldest son might be the primary heir, much like in traditional Chinese culture.
- Aboriginal Cultures in Australia: Aboriginal cultures in Australia have a unique perspective on wealth transfer. Instead of viewing property as an individual possession, many Indigenous cultures have a communal concept of ownership. In this context, wealth transfer isn’t about passing assets from one individual to another but maintaining the communal wealth of the group. However, with the imposition of Western legal systems, some Aboriginal Australians have started to engage with practices like drafting wills. The process is often complicated by the tension between traditional customs and Western legal norms.
Remember, these are broad overviews and individual practices can vary significantly within each culture. Cultural norms evolve over time, influenced by factors such as urbanisation, globalisation, changes in legal frameworks, and individual family values and circumstances. In our increasingly globalised world, we’re also seeing more intermingling of these traditions as people move across borders and cultures mix.