WhereNext Open Data
Inheritance & Estate Tax by Country 2026
What happens to your estate — and your heirs' inheritance — across 24 popular relocation destinations. Who's exempt, the top rate a distant heir can face, and the part that catches expats out: whether non-residents are taxed on worldwide assets or only local ones.
Quick answer
Of 24 popular relocation destinations, 13 levy no inheritance or estate tax at all — including Portugal, Malta, Cyprus, Sweden, United Arab Emirates. Most continental-European systems tax the beneficiary (with large spouse and child allowances), while the US and UK tax the estate. The steepest top rate a beneficiary can face is 60% (France). The biggest expat trap is the US: non-residents owning US real estate or US stocks face up to 40% estate tax on anything above just $60,000 of US-situs assets. The UK's April 2025 reform also pulls your worldwide estate into scope once you've been UK-resident 10 of the last 20 years.
Key facts
- 13 of 24 destinations: 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 stamp duty on transfers (Portugal, Malta).
- US $60,000 situs trap Non-US persons owning US real estate or US-listed stocks face up to 40% US estate tax above just $60,000 — versus a ~$15M exemption for US citizens (2026).
- UK April-2025 reform The test moved from domicile to residence: once UK-resident 10 of the last 20 years, your worldwide estate is in scope at 40% above ~£325k–£500k.
- Spouses + children usually win Portugal, Italy (€1M allowance + 4%), France, Germany (€400k–€500k allowances) and others heavily favour close family; Portugal and many no-tax countries charge them nothing.
- Steepest distant-heir rates France (60%) and some Swiss cantons (~50%) top the table for unrelated beneficiaries; regional rules (Spain, Switzerland, Germany) swing the bill dramatically.
| Country | Model | Spouse | Children (top) | Distant (top) |
|---|---|---|---|---|
| Malta | None | — | — | — |
| Cyprus | None | — | — | — |
| Sweden | None | — | — | — |
| United Arab Emirates⚠ | None | — | — | — |
| Singapore | None | — | — | — |
| Malaysia | None | — | — | — |
| Mexico | None | — | — | — |
| Panama | None | — | — | — |
| Costa Rica | None | — | — | — |
| Australia⚠ | None | — | — | — |
| Canada⚠ | CGT at death | Exempt | — | — |
| New Zealand | None | — | — | — |
| Portugal⚠ | Stamp duty | Exempt | — | 10% |
| Italy | Beneficiary | Exempt | 4% | 8% |
| Thailand | Estate tax | Exempt | 5% | 10% |
| Ireland | Beneficiary | Exempt | 33% | 33% |
| Spain⚠ | Beneficiary | Partial | 34% | 34% |
| United States⚠ | Estate tax | Partial | 40% | 40% |
| United Kingdom⚠ | Estate tax | Exempt | 40% | 40% |
| Greece | Beneficiary | Partial | 10% | 40% |
| Netherlands | Beneficiary | Partial | 20% | 40% |
| Germany | Beneficiary | Partial | 30% | 50% |
| Switzerland⚠ | Beneficiary | Exempt | 26% | 50% |
| France | Beneficiary | Exempt | 45% | 60% |
Top rates shown are top marginal rates; most close-family inheritances pay far less after allowances. “—” means no tax or fully exempt. ⚠ marks an expat trap worth reading below.
Expat traps worth knowing
- 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.
Inheritance tax abroad, answered
Which countries have no inheritance tax?
13 of the 24 countries in this dataset levy no inheritance or estate tax at all: Portugal, Malta, Cyprus, Sweden, United Arab Emirates, Singapore, Malaysia, Mexico and 5 others. That is the position for a resident estate — several still tax property located in the country when the owner lived elsewhere, so check the non-resident column before assuming an estate is out of scope.
Which country taxes an inheritance left to a child most heavily?
Of the countries that tax inheritances to direct descendants, France has the highest top marginal rate at 45%, followed by United States (40%) and United Kingdom (40%). These are top marginal rates: most close-family inheritances pay considerably less once allowances apply — France's allowance position is "€100,000 allowance per child, then progressive 5%–45%.".
Does a surviving spouse pay inheritance tax?
In 8 of the 24 countries covered, a surviving spouse is fully exempt. The rest range from partial relief to taxing the spouse like any other heir, so a couple's exposure can differ enormously between two countries that look similar on the headline rate. Spouse treatment is listed per country in the table above.
Is it more expensive to leave an inheritance to someone who is not family?
Substantially, in most systems that tax inheritance at all. The top rate for an unrelated beneficiary reaches 60% in France, against 45% for a child there. Unmarried partners are treated as unrelated in several of these systems, which is the most common way this catches people out.
What catches expats out with inheritance tax?
8 countries in this dataset carry a documented trap for people who moved there or hold assets there — the table flags each one. They cluster around three things: tax that follows domicile rather than residence long after you leave, property in the country being taxed regardless of where the owner lived, and forced-heirship rules that override a foreign will.
How current is this inheritance tax data?
Every row was last verified on 2026-06-30, and each carries its own source and verification date in the table. Inheritance tax rules change with national budgets, so re-check the linked source before acting on any figure — this dataset is decision support, not tax advice.
Methodology
- One record per country: tax model (estate vs beneficiary vs none), spouse + direct-descendant treatment, top distant-heir rate, and non-resident basis.
- Rates are top marginal rates. Actual bills depend on relationship, allowances, asset type, and amount.
- “No inheritance tax” can still mean capital gains at death (Canada deemed disposition, Australia CGT) or a transfer stamp duty (Portugal 10%, Malta 5%).
- Regional systems (Spain by comunidad, Switzerland by canton, Germany by class) vary substantially below the national level — tagged medium confidence.
- Directional comparison only — not legal or tax advice. Confirm with a cross-border estate-planning advisor.
Sources: PwC Worldwide Tax Summaries, national tax authorities, and Big-Four / law-firm country guides (2025–2026). Full methodology
Plan your move with the full picture
Inheritance tax is one piece — see how a destination scores overall
Estate exposure sits alongside income tax, cost of living, healthcare, and visa access in any real relocation decision. Start a free case and WhereNext builds you a personalized roadmap across all of them — no estate-tax data is ever attached to your profile.
Start a free relocation case →How to cite this data:
WhereNext. "Inheritance & Estate Tax by Country 2026." getwherenext.com/data/inheritance-tax-2026. Accessed 2026-06-30.
Licensed under CC BY 4.0. Free to use with attribution.
Suggested citation
CC BY 4.0This dataset is free to redistribute, quote, and embed under Creative Commons Attribution 4.0. The composite form below preserves source lineage so AI assistants can cite both WhereNext and the underlying institutional publishers.
WhereNext composite — Inheritance & Estate Tax 2026 (2026-06-30). Derived from: PwC Worldwide Tax Summaries (2025-2026); National revenue authorities (IRS, HMRC, AEAT, AdE, BMF, DGFiP, etc.); Big-Four / law-firm country estate-tax guides; WhereNext curated comparative research. Available at https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation. CC BY 4.0.
WhereNext. (2026). Inheritance & Estate Tax 2026. Retrieved from https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation. CC BY 4.0.
WhereNext. "Inheritance & Estate Tax 2026." WhereNext, 30 Jun 2026, https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation. Accessed via https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation. CC BY 4.0.
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author = {{WhereNext}},
title = {Inheritance & Estate Tax 2026},
year = {2026},
url = {https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation},
note = {CC BY 4.0}
}<a href="https://getwherenext.com/data/inheritance-tax-2026?utm_source=internal&utm_medium=citation&utm_campaign=data-citation">WhereNext — Inheritance & Estate Tax 2026</a>
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