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Library guide · Jurisdiction Strategy

Inheritance Tax by Country (2026)

Where inheritance and estate tax bites hardest, where there is none, and the traps for international families.

Last updated 8 August 2026 · 3 min read

Inheritance and estate tax varies enormously by country. The US and UK tax at 40 percent, France reaches 60 percent for distant heirs, while many countries, including the UAE, Portugal, Sweden and Cyprus, levy none. But no inheritance tax is not the same as no tax, and international families face specific traps such as the US 60,000 dollar exemption for non-residents.

Key takeaways

  • High: France up to 60 percent (distant heirs); US and UK 40 percent.
  • None: many countries levy no inheritance or estate tax, including the UAE, Portugal, Sweden, Cyprus and others (about 13 of 24 popular destinations).
  • US trap: non-residents get only a 60,000 dollar exemption on US assets, versus about 15 million dollars for US citizens (2026).
  • UK shift: from April 2025, worldwide estates of long-term residents are taxed at 40 percent, with a tail after leaving.

Where you die, and where your assets sit, can change how much of your estate reaches your heirs by tens of percentage points. Inheritance tax is one of the least harmonised taxes in the world, and for an international family the differences are enormous. This is a directional comparison, not tax advice.

Inheritance tax rates by country, at a glance

The table below gives indicative top rates. Click a column to sort, or filter by country. Rates are the highest applicable and often fall sharply for spouses and children; see the notes and the sources below.

CountryTop inheritance or estate taxNotes
FranceUp to 60%Distant heirs; spouses and children taxed far more lightly
JapanUp to 55%Among the highest rates in the world
South KoreaUp to 50%High progressive rates on large estates
Germany7% to 50%Rate depends on relationship and amount
NetherlandsUp to 40%Progressive, by relationship
United Kingdom40%Residence-based from April 2025; nil-rate bands apply
United States40%About 15M dollars exemption for citizens; only 60k for non-residents on US assets
SpainRegional, up to about 34%+Varies widely by region
Ireland33%Capital acquisitions tax
SwitzerlandCantonal; often 0% for close familySpouses and children frequently exempt
UAE0%No inheritance tax
Portugal0% (10% stamp on some transfers)Close family exempt; stamp duty for others
Sweden0%Abolished
Cyprus0%No inheritance tax
Malta0%No inheritance tax
Singapore0%Abolished in 2008
Australia0%No inheritance tax
Canada0% (capital gains on death)No estate tax, but a deemed disposition triggers capital gains

Where it bites hardest

At the top of the table sits France, where distant heirs can face rates up to 60 percent (though spouses and children are treated far more gently). The US and the UK both levy 40 percent. Much of continental Europe taxes the beneficiary on what they receive, with large allowances for spouses and children but higher rates for others.

Where there is none

At the other extreme, many countries levy no inheritance or estate tax at all, including the UAE, Portugal, Sweden, Cyprus, Malta, Australia and New Zealand; by one count, about 13 of 24 popular relocation destinations. This is part of what draws wealthy families to jurisdictions like the UAE. But a crucial caveat: no inheritance tax is not the same as no tax. Income, gains and other taxes may still apply.

The traps for international families

Two catch people repeatedly:

  • The US non-resident trap. A non-US person who owns US-situs assets, such as US real estate or US-listed shares, gets an exemption of only 60,000 dollars, above which the estate faces up to 40 percent US estate tax, versus roughly a 15 million dollar exemption for US citizens and residents (2026). Owning US assets without planning can be very costly.
  • The UK residence shift. From April 2025, once you have been UK-resident for 10 of the last 20 years, your worldwide estate is in the UK 40 percent net, and that exposure lingers for three to ten years after you leave.

What to do about it

The tools are the ordinary ones of good planning: trusts and holding structures, lifetime gifting, life insurance for liquidity, and careful residence planning, all coordinated across the relevant countries, since inheritance-tax treaties are far rarer than income-tax treaties. See What Is Estate Planning? and Best Countries for Tax Residency.

Frequently asked questions

Which countries have the highest inheritance tax?
France tops the table at up to 60 percent for distant heirs (spouses and children are taxed far more lightly). The US and UK both levy 40 percent. Several other European countries apply progressive rates that can be high for non-close relatives.
Which countries have no inheritance tax?
Many, including the UAE, Portugal, Sweden, Cyprus, Malta, Australia, New Zealand and others; roughly half of popular relocation destinations levy no inheritance or estate tax. But no inheritance tax does not mean no tax at all: other taxes and rules still apply.
What is the inheritance tax trap for international families?
Two big ones. The US taxes non-residents on US assets (US real estate, US stocks) above just 60,000 dollars at up to 40 percent, versus about a 15 million dollar exemption for US citizens. And the UK, from April 2025, taxes long-term residents' worldwide estates at 40 percent, with exposure lingering three to ten years after they leave.

This guide is educational and general in nature. It does not constitute investment, legal, tax or financial advice.