Inheritance Tax by Country
Inheritance tax rules differ enormously across the world — from Japan's 55% top rate to the absence of any estate tax in Australia, Canada, Singapore, and the UAE. This reference covers top rates, spouse and child exemptions, and treaty notes for the jurisdictions most relevant to international relocators and heirs of cross-border estates.
Last reviewed: 2026-05-09. Inheritance tax rules change with national budgets — this is general information, not legal or tax advice. Consult a qualified estate planner before relying on any row.
| Country | IHT | Top rate | Spouse exemption | Child exemption / notes |
|---|---|---|---|---|
| Belgium | Yes | 80% (distant relatives, Walloon Region, top bracket) | Variable by region. Flanders: cohabitation legal partner eligible for spouse rates. | Region-dependent. Flanders: 3%-27% direct line. Wallonia: 3%-30%. Brussels-Capital: 3%-30%. Belgium's regional inheritance tax is among the most complex in Europe — three regions (Flanders, Wallonia, Brussels) with distinct rate cards and exemptions. Top stranger rates can reach 80% in Wallonia. Domicile of the deceased determines which region's rules apply. |
| Denmark | Yes | 36.25% (close family + distant; specific multi-rate structure) | Unlimited — spouses fully exempt. | DKK 343,800 (~$50,000) bottom-line exemption (2024). Direct heirs (children, parents, surviving spouse to extent inheritance exceeds the spousal exemption): 15% above the threshold. Other heirs: 25% supplementary tax on top of the 15%, totalling 36.25%. Among Europe's lower rates. |
| France | Yes | 60% (between strangers and distant relatives); 45% (direct descendants above €1.8M) | 100% — spouses and PACS partners are entirely exempt from inheritance tax. | €100,000 per child per parent, plus progressive rates 5%-45% above. France applies forced heirship: children take a reserved share (50% with one child, 67% with two, 75% with three or more). Surviving spouse can elect for usufruct or 25% of estate. Fixed Bordereau holds heirs jointly liable for inheritance tax filing within 6 months of death (12 months if death occurred abroad). |
| Germany | Yes | 50% (Class III, distant relatives, above €26M) | €500,000 personal allowance plus €256,000 pension-equivalent allowance. | €400,000 per child per parent, plus €52,000-€10,300 pension-equivalent allowance depending on child age. Germany has Class I (spouse, children, parents — 7%-30%), Class II (siblings, in-laws — 15%-43%), Class III (others — 30%-50%) bracket structure. Major business-succession reliefs available — controlling business interests can qualify for 85%-100% Verschonungsabschlag if held for 5-7 years post-inheritance. |
| Greece | Yes | 40% (Category C, others) | €800,000 (Category A spouse + children allowance). | Same Category A allowance shared with spouse. Greek inheritance tax has three categories: A (spouse, children, parents) 1%-10%; B (other family) 5%-20%; C (others) 20%-40%. Real estate is valued at the Antikeimeniki Axia (objective tax value), often well below market. The €100,000 HNWI flat-tax regime can be elected on death only if the deceased was registered for it. |
| Ireland | Yes | 33% Capital Acquisitions Tax (CAT) | Unlimited. | €400,000 lifetime aggregate (Group A threshold from 2 October 2024, up from €335,000). Ireland uses Capital Acquisitions Tax — a tax on the recipient (heir) rather than the estate. Three group thresholds: A (children + dependent parents) €400,000; B (siblings, nieces/nephews, lineal ancestors/descendants beyond children) €40,000; C (others) €20,000. Aggregate lifetime — gifts and inheritances combined. |
| Italy | Yes | 8% (between strangers / distant relatives) | €1 million per spouse exempt. | €1 million per child per parent exempt. Italy has among Europe's lowest IHT rates: 4% (spouse + direct descendants above €1M each), 6% (siblings above €100k each, plus other relatives no exemption), 8% (others no exemption). The high €1M direct-line exemption means most inheritances fall entirely outside scope. |
| Japan | Yes | 55% on amounts above ¥600M (~$4M) per heir | ¥160M (~$1M) statutory minimum, or 50% of statutory share, whichever is greater. | ¥30M base + ¥6M per statutory heir. Japan's 55% top rate is the highest in the world. Heirs (not estates) are taxed. Foreign nationals living in Japan over 10 years out of 15 are subject to worldwide-assets inheritance tax — a notable trap for long-stay expats. Spouses can defer tax on the spousal share. |
| Netherlands | Yes | 40% (distant relatives / strangers) | €795,156 (2025). | €25,187 per child per parent (2025); higher for disabled children. Spouse + child rates are 10%-20%. Sibling/other-relative rates 18%-36%. Distant-relative/stranger rates 30%-40%. Dutch tax residents pay IHT on worldwide assets; non-residents only on Dutch real estate. |
| South Korea | Yes | 50% above ₩3 billion (~$2.2M) | Statutory deduction of ₩500M plus a percentage of the statutory share. | ₩50M per child plus a basic estate deduction of ₩500M. South Korea's 50% top rate plus an additional 20% surcharge for inheriting controlling stakes (above 50% of corporate ownership) effectively pushes top marginal rate near 60%. Major driver of corporate restructuring among Korean chaebol families. |
| Spain | Yes | 34% national + autonomous-community surtaxes (up to 87% in some scenarios) | Highly variable by autonomous community. Madrid, Andalusia, La Rioja: 99% bonification (effective near zero). Catalonia, Asturias: standard rates apply. | Same regional variation. Madrid/Andalusia: ~99% reduction. Other regions: €15,956-€47,859 base allowance. Spain's regional variation is extreme — moving inheritance to Madrid before death can reduce IHT bills by 99% versus inheritance in Catalonia. Non-resident heirs of Spanish-situs assets historically paid full state rates but ECJ ruling forced regional treatment in cross-border EU/EEA cases. |
| United Kingdom | Yes | 40% above the threshold | Unlimited (UK-domiciled spouse). Cap of £325k for transfers to non-UK-domiciled spouse, plus £325k nil-rate band. | £325,000 nil-rate band per estate, plus £175,000 residence-nil-rate band when primary residence passes to direct descendants. From April 2025 the UK moved from a domicile-based to a residence-based IHT system. Long-term residents (10+ years of last 20) become subject to UK IHT on worldwide assets; previously non-doms could escape via the remittance regime. Major planning shift for UK-resident HNWIs. |
| United States | Yes | 40% federal estate tax | Unlimited (US-citizen spouse). Non-US-citizen spouse: only $190,000/yr annual exclusion plus QDOT trust. | Subject to lifetime $13.99M (2025) unified estate-and-gift exemption — no separate per-heir cap. The $13.99M (single) / $27.98M (couple) federal exemption sunsets 31 December 2025 absent congressional action — reverting to ~$7M-indexed. Some US states (MA, NY, OR, WA) levy their own estate tax with much lower thresholds ($1M-$2M). Non-resident aliens face only $60,000 exemption on US-situs assets — major planning trap. https://www.irs.gov/businesses/small-businesses-self-employed/estate-and-gift-taxes |
| Portugal | Limited | 10% (Stamp Duty — only on non-direct-line heirs) | Unlimited — spouse, descendants, and ascendants entirely exempt. | Unlimited — direct line exempt. Portugal abolished classical inheritance tax in 2004. Replaced by Stamp Duty (Imposto do Selo) at a flat 10% on inheritances and gifts to non-direct-line beneficiaries (siblings, nieces/nephews, others). Spouse, children, parents, grandchildren, grandparents are entirely exempt — making Portugal one of the most estate-tax-friendly developed countries. |
| Switzerland | Limited | Up to ~50% (Geneva, Zurich, distant relatives) | 100% in all 26 cantons — spouses are exempt nationwide. | 100% in 24 of 26 cantons. Vaud and Appenzell-Innerrhoden levy small rates on direct descendants (~1%-3%). Switzerland has no federal inheritance tax. Cantons set their own — most exempt direct line entirely. Strangers and distant relatives face the highest rates (Geneva, Vaud, Zurich). The Lump-Sum Taxation regime does not extend to inheritance — heirs of a forfait taxpayer face standard cantonal IHT. |
| Australia | None | — | — | — Australia abolished federal estate duty in 1979. No state-level inheritance tax. Capital gains tax may still apply if inherited assets are later sold (with cost-base step-up at the date of death only for pre-CGT assets — post-1985 assets retain original cost base). |
| Austria | None | — | — | — Austria abolished inheritance tax in 2008 after the Constitutional Court ruled the regime unconstitutional. Real estate transfers on death still attract a 2%-3.5% real-estate-acquisition tax (Grunderwerbsteuer). |
| Canada | None | — | — | — Canada has no inheritance or estate tax. However, the deceased's estate is deemed to dispose of all capital assets at fair market value at death — triggering capital-gains tax on accumulated unrealised gains, often called the 'death tax' colloquially. Spousal rollover defers the deemed disposition to the surviving spouse. |
| Czech Republic | None | — | — | — Czech Republic abolished inheritance tax effective 2014. No estate, inheritance, or gift tax for direct-line heirs. Distant-relative or third-party gifts may be subject to ordinary income tax. |
| Estonia | None | — | — | — Estonia has never had inheritance tax. No estate, gift, or net-worth tax. Combined with the deferred corporate-tax system, Estonia is one of the most tax-favoured EU jurisdictions for wealth holding. |
| Hong Kong | None | — | — | — Hong Kong abolished its estate duty in February 2006. No inheritance, estate, or gift tax. Combined with territorial taxation system and no capital gains, a key element of HK's wealth-management appeal. |
| Israel | None | — | — | — Israel abolished inheritance tax in 1981. No estate or gift tax. Capital gains continuity rule applies on inherited assets — heirs inherit original cost basis. Major draw for wealthy diaspora considering Aliyah. |
| Mexico | None | — | — | — Mexico has no federal inheritance tax. Income from foreign inheritances received by Mexican tax residents is exempt up to ~$2M USD lifetime; above that, ordinary income tax applies. Some Mexican states levy small property-transfer taxes on death. |
| New Zealand | None | — | — | — NZ abolished estate duty in 1992 and gift duty in 2011. No capital-gains tax either, except limited bright-line tests on certain residential property and trader-classification activities. Among the most estate-planning-friendly developed countries. |
| Norway | None | — | — | — Norway abolished inheritance tax in January 2014. Capital-gains continuity rule means heirs inherit assets at original cost basis (no step-up). |
| Saudi Arabia | None | — | — | — No inheritance tax. Sharia rules govern Muslim estates by default. Saudi Arabia levies Zakat (2.5% annual on wealth) only on Saudi nationals and GCC nationals. |
| Singapore | None | — | — | — Singapore abolished its estate duty in February 2008. No inheritance, estate, or gift tax. Combined with absence of capital-gains tax on most assets, makes Singapore one of the most estate-tax-friendly major financial centres. |
| Sweden | None | — | — | — Sweden abolished inheritance tax in 2004 and gift tax in 2005. The decision (taken by a Social Democratic government) cited capital-flight pressure and administrative complexity. |
| United Arab Emirates | None | — | — | — The UAE has no inheritance tax. Sharia inheritance rules apply by default to Muslim estates and to non-Muslim estates of UAE residents who do not opt out. Non-Muslim residents can elect home-country law for estates via DIFC Wills Service or Abu Dhabi Judicial Department non-Muslim inheritance procedure. |
Reading this matrix
- Estate vs inheritance tax.US, UK, and a few others tax the estate (the deceased's pool of assets). Most other countries tax inheritances received by each heir, with separate exemptions per recipient. The economic difference is significant when assets pass through multiple heirs.
- Domicile vs residence.Some countries (historically the UK, Ireland) tax based on domicile of the deceased; others (Germany, France) tax based on either the deceased's residence or the heir's residence (whichever applies). Conflicts can produce double taxation.
- Spousal exemptions vary widely. Most continental-European countries fully exempt spouses. Anglo jurisdictions (US, UK) provide unlimited spousal transfer within marriage but cap or convert it for non-citizen spouses (e.g. US QDOT trust requirement).
- Treaty network. Bilateral inheritance-tax treaties exist but are far rarer than income-tax treaties. The US has 15 estate-tax treaties (UK, France, Germany, Netherlands, Switzerland, Austria, Denmark, Finland, Greece, Ireland, Italy, Japan, Norway, South Africa, Sweden) — most other cross-border estates rely on unilateral foreign-tax credit relief.
- Forced heirship in France, Germany, Italy, Spain, Belgium, Switzerland, Greece, and most of Latin America constrains how much of an estate can be left to non-children. This is a separate civil-law overlay — even where IHT is modest, mandatory shares to direct descendants may still apply.
See also: Wealth tax matrix · Tax residency matrix.