Quick answer
Inheritance tax by country: the decision table (2026)
13 of the 24 countries in our registry charge no inheritance or estate tax at all; where it applies, the top rate for a child ranges from 4% to 45%.
| Country | Tax model | Spouse | Children top rate | Unrelated heir top rate | Non-residents taxed on | Verified |
|---|---|---|---|---|---|---|
| Australia | None | Not applicable | — | — | Local assets | |
| Canada | Deemed disposition | Exempt | — | — | Local assets | |
| Costa Rica | None | Not applicable | — | — | None | |
| Cyprus | None | Not applicable | — | — | None | |
| Malaysia | None | Not applicable | — | — | None | |
| Malta | None | Not applicable | — | — | None | |
| Mexico | None | Not applicable | — | — | None | |
| New Zealand | None | Not applicable | — | — | None | |
| Panama | None | Not applicable | — | — | None | |
| Singapore | None | Not applicable | — | — | None | |
| Sweden | None | Not applicable | — | — | None | |
| United Arab Emirates | None | Not applicable | — | — | None | |
| Portugal | Stamp duty | Exempt | — | 10% | Local assets | |
| Italy | Inheritance tax | Partial relief | 4% | 8% | Worldwide or local assets | |
| Thailand | Estate tax | Exempt | 5% | 10% | Worldwide or local assets | |
| Ireland | Inheritance tax | Exempt | 33% | 33% | Worldwide or local assets | |
| Spain | Inheritance tax | Partial relief | 34% | 34% | Local assets | |
| Greece | Inheritance tax | Partial relief | 10% | 40% | Local assets | |
| Netherlands | Inheritance tax | Partial relief | 20% | 40% | None | |
| United Kingdom | Estate tax | Exempt | 40% | 40% | Worldwide or local assets | |
| United States | Estate tax | Partial relief | 40% | 40% | Local assets | |
| Germany | Inheritance tax | Partial relief | 30% | 50% | Worldwide or local assets | |
| Switzerland | Inheritance tax | Exempt | 26% | 50% | Local assets | |
| France | Inheritance tax | Exempt | 45% | 60% | Worldwide or local assets |
How to read this: the model says who is charged; top rates are marginal rates before allowances. Residency, domicile, treaties, asset location, and regional rules can change a real outcome.
Registry updated . Sources: PwC Worldwide Tax Summaries and national tax authorities; see the full source-backed dataset for country notes.
Key facts
- 13 of 24 destinations have no inheritance tax Portugal, Malta, Cyprus, Sweden, United Arab Emirates, Singapore, Malaysia, Mexico, Panama, Costa Rica, Australia, Canada, New Zealand — though some still levy capital gains at death (Canada, Australia) or a transfer stamp duty (Portugal 10%, Malta 5%).
- US $60,000 non-resident estate trap Non-US persons owning US real estate or US-listed stocks face up to 40% US estate tax above just $60,000 of US-situs assets — versus a ~$15M exemption for US citizens (2026).
- UK moved from domicile to residence in April 2025 Once you've been UK-resident 10 of the last 20 years, your worldwide estate is in scope at 40% above the ~£325k–£500k bands — and it lingers after you leave.
- Steepest top rate: France at 60% France tops the table for distant heirs (60%); spouses and children, by contrast, are exempt or lightly taxed almost everywhere.
Important
This guide is a directional comparison for relocation decisions, not legal or tax advice. Inheritance and estate tax depend on residency, domicile, tax treaties, asset location, and (in Spain, Switzerland, and Germany) sub-national rules. Confirm your situation with a qualified cross-border estate-planning advisor before acting. Figures draw from our Inheritance & Estate Tax 2026 open dataset (PwC Worldwide Tax Summaries + national tax authorities).
Estate tax vs inheritance tax: two different systems
People use “inheritance tax” loosely, but two genuinely different systems sit behind the phrase, and the difference changes who pays and how much.
An estate tax is charged on the deceased person's whole estate before anything is distributed — the estate pays, then heirs split what's left. The United States and the United Kingdom work this way. An inheritance tax (the continental European model — France, Germany, Italy, Spain) is charged on each beneficiary, with the rate and allowance depending on how closely related they were to the deceased. A spouse or child typically gets a large tax-free band; a distant relative or unrelated friend gets little or none and a much higher rate.
A third group has no inheritance or estate tax at all — but watch for substitutes: Canada triggers a “deemed disposition” (capital gains as if you sold everything at death), Australia can hit inherited assets with capital gains tax on a later sale, and Portugal and Malta levy a transfer stamp duty instead.
Countries with no inheritance tax
For many movers — especially retirees and those holding family wealth — the simplest win is a destination that doesn't tax inheritance at all. Of the 24 destinations we track, 13 fall into this group:
- Portugal: No inheritance tax. Close family inherit tax-free; other heirs pay a flat 10% stamp duty on Portuguese assets.
- Malta: No inheritance/estate/gift tax; only a 5% stamp duty on inherited Maltese property.
- Cyprus: No inheritance or estate tax — abolished in 2000.
- Sweden: No inheritance, estate or gift tax — abolished in 2004/2005.
- United Arab Emirates: No inheritance or estate tax; register a will (DIFC/ADGM) to override default Sharia succession.
- Singapore: No estate or inheritance tax — estate duty abolished in 2008.
- Malaysia: No inheritance or estate tax — estate duty abolished in 1991.
- Mexico: No federal inheritance tax; a March 2025 initiative filed in the Congress of Mexico City proposed amending the federal Income Tax Law to tax inheritances above MXN 15 million, but it is not current law.
- Panama: No inheritance, estate or gift tax — a popular feature of Panama's territorial system.
- Costa Rica: No inheritance or estate tax; only modest property-transfer and annual property taxes.
- Australia: No inheritance tax, but watch capital gains tax on later sale — foreign-resident heirs lose the home exemption.
- Canada: No estate or inheritance tax — instead, death triggers a 'deemed disposition' and capital gains on the final tax return.
- New Zealand: No estate, inheritance or gift tax — and no general capital gains tax either.
The catch: “no inheritance tax” is not always “nothing to pay.” Canada's deemed-disposition capital-gains bill at death can be substantial; Australia's CGT bites when a foreign-resident heir later sells inherited property; and Portugal's 10% stamp duty still applies to non-direct heirs on Portuguese assets (spouses and children are exempt).
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Compare all 24 countries in the open datasetInheritance & estate tax: the countries that do charge it
Among the destinations that levy the tax, the headline rate a distant heir can face ranges from 8% in Italy to 60% in France. But the top rate is rarely what a close family member actually pays — most systems give spouses and children generous allowances first. The table below shows the top marginal rate for a child and for an unrelated heir, plus how non-residents are treated.
| Country | Model | Children (top) | Distant (top) |
|---|---|---|---|
| Italy | Beneficiary | 4% | 8% |
| Thailand | Estate tax | 5% | 10% |
| Ireland | Beneficiary | 33% | 33% |
| Spain | Beneficiary | 34% | 34% |
| United States | Estate tax | 40% | 40% |
| United Kingdom | Estate tax | 40% | 40% |
| Greece | Beneficiary | 10% | 40% |
| Netherlands | Beneficiary | 20% | 40% |
| Germany | Beneficiary | 30% | 50% |
| Switzerland | Beneficiary | 26% | 50% |
| France | Beneficiary | 45% | 60% |
Italy is the standout for families: a €1,000,000 allowance per child and a flat 4% above it, with 8% the most an unrelated heir ever pays. Germany (€400k per child, €500k spouse) and the Netherlands (~€800k partner exemption) are similarly generous to close family. France exempts spouses entirely but reaches 60% for unrelated heirs — the steepest in our set.
The expat traps worth knowing
The mistakes that cost real money are rarely about the headline rate — they're about which assets a country reaches and when you become exposed. These are the ones that catch movers out:
- United States: Non-US persons owning US real estate or US stocks face up to 40% US estate tax on anything above $60,000 of US-situs assets — a common, overlooked trap.
- United Kingdom: April 2025 reform: once you've been UK-resident 10 of the last 20 years, your WORLDWIDE estate is in scope — and it lingers after you leave. From 6 April 2026, 100% agricultural/business property relief is capped at a £2.5M combined allowance (50% relief above), so family-farm and business estates above that face up to ~20% IHT.
- Portugal: A favourite for retirees: spouse and children inherit Portuguese assets with zero tax.
- Spain: Location is the whole game: regional rebates can take close-family bills near zero, while multiplier coefficients (up to 2.4×) can push a distant, wealthy heir's effective rate toward ~82%.
- Switzerland: There is no national rate — the canton of residence (or of the property) decides everything.
- United Arab Emirates: No tax, but without a registered will, assets are distributed under Sharia rules — expats should plan succession explicitly.
- Australia: Inheriting then selling Australian property as a foreign resident can trigger CGT with no main-residence relief.
- Canada: It's not an inheritance tax, but the deemed-disposition capital-gains bill at death can be substantial.
The two that surprise people most: the US $60,000 situs trap and the UK's 2025 residence rule. If you're not American but you own a Miami condo or hold US-listed ETFs in a brokerage account, the IRS can tax your estate up to 40% on everything above $60,000 of US-situs assets — a threshold unchanged for decades and unrelated to the multi-million-dollar exemption US citizens enjoy. And if you've lived in the UK long enough (10 of the last 20 years), Britain now taxes your worldwide estate, a reach that persists for years after you leave.
Generic tax rates don't tell you what you'd actually owe
Your effective rate depends on your income, filing status, FEIE eligibility, and destination regime. This report models your exact scenarios and gives your CPA a handoff brief.
This plan is not currently for sale while its figures are being re-verified against their sources.
Read the sample first →How non-residents are taxed: worldwide vs local assets
The single most important question for a mover is not the rate — it's the basis: does the country tax your worldwide estate, or only assets physically located there (“situs” assets)?
Most countries tax non-residents only on local-situs assets — a French apartment, a German bank account, Spanish property. That means you can often hold the bulk of your wealth elsewhere and limit exposure to the specific assets you keep in-country. The exceptions are the ones to plan around: the US reaches non-residents' US-situs assets aggressively (the $60k threshold), and the UK and several others switch to a worldwide basis once you cross a residency threshold. Tax treaties (for example the US–UK estate tax treaty) can raise exemptions or resolve double-taxation — another reason cross-border cases need professional review.
Inheritance tax is only one line in a relocation decision. If you want to see how a destination stacks up across cost of living, income tax, healthcare, safety, and visa access at the same time, start a free relocation case — WhereNext builds you a personalized roadmap, and you can model income tax separately with the tax comparison tool or browse the full income tax rates dataset.
Frequently Asked Questions
Which countries have no inheritance tax?▾
Of the 24 popular relocation destinations we track, 13 levy no inheritance or estate tax: Portugal, Malta, Cyprus, Sweden, United Arab Emirates, Singapore, Malaysia, Mexico, Panama, Costa Rica, Australia, Canada and New Zealand.
Do I pay inheritance tax if I move abroad?▾
It depends on the country's basis. Most tax non-residents only on assets located there (real estate, local accounts). Some — notably the UK after April 2025, once you've been resident 10 of the last 20 years — tax your worldwide estate. The US taxes non-residents on US-situs assets (real estate, US stocks) above just $60,000 at up to 40%. Always confirm your residency and domicile position with a cross-border advisor.
What is the US estate tax for non-residents?▾
Non-resident, non-citizen owners of US-situs assets (US real estate, US-listed stocks) get only a $60,000 exemption, after which the estate faces up to 40% US estate tax and must file Form 706-NA. This contrasts sharply with the ~$15M exemption (2026) for US citizens and residents. A relevant estate tax treaty (e.g. US–UK) can increase the effective exemption.
Did UK inheritance tax change in 2025?▾
Yes. From April 2025 the UK replaced the old domicile test with a residence-based one. If you've been UK-resident for 10 of the last 20 years you are a 'long-term resident' and your worldwide estate is within the scope of the 40% inheritance tax (above the ~£325,000 nil-rate band, plus up to £175,000 residence nil-rate band). The exposure can persist for several years after you leave the UK.
Which country has the highest inheritance tax?▾
Among our 24 destinations, France has the steepest top rate at 60% for unrelated/distant heirs. Spain's state scale tops out around 34% but multiplier coefficients can push a distant, wealthy heir's effective rate toward ~82% — while close family in regions like Madrid and Andalucía are rebated ~99%. Germany and some Swiss cantons reach ~50% for distant heirs. Spouses and children, by contrast, are exempt or lightly taxed in most systems.
Which countries have the highest inheritance tax?▾
The three highest top marginal rates for an unrelated heir in this registry are France (60%), Germany (50%) and Switzerland (50%). Allowances and regional rules can reduce the bill for close family, so compare the model and relationship columns as well as the headline rate.
Do expats pay inheritance tax on foreign assets?▾
It depends on the non-resident basis recorded for the country and the facts of residence, domicile, and asset location. Registry examples: United Kingdom — From April 2025 the test is residence-based: 'long-term residents' (UK-resident 10 of the last 20 years) are taxed on worldwide assets; others on UK-situs assets only. United States — Non-resident non-citizens are taxed only on US-situs assets, but the exemption collapses to just $60,000. Netherlands — Generally only applies if the deceased was a Dutch resident (a 10-year reach-back applies to Dutch nationals); non-residents' estates are largely out of scope.
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See the full inheritance & estate tax dataset