Inheritance tax, also known as estate tax or death tax, is a tax that is imposed on the transfer of property or assets from a deceased individual to their heirs or beneficiaries. Inheritance tax laws vary widely across different countries, with some nations imposing very high taxes on estates while others have no such taxes at all. In this article, we will explore the inheritance tax laws of all major countries around the world, highlighting the differences and similarities between them.
All countries are listed alphabetically.
Keep in mind that countries may change their inheritance tax rates and exemption amounts regularly. Exemption amounts in particular are updated frequently to adjust for inflation. The information shown here is based on 2021 data. While we try to keep information up to date, it is always best to check with local tax authorities directly. Consider this guide as a starting point comparing inheritance tax rules across countries.
While the majority of countries do tax inheritances, these can usually be avoided by setting up special purpose vehicles to hold international assets. This is where we can help.
Argentina
Argentina does not have a federal inheritance tax.
The province of Buenos Aires, however, introduced local inheritance tax rate ranges from 0.5% to 8%, depending on the value of the estate and the relationship between the deceased and the beneficiary. Immediate family members are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals.
Australia
In Australia, inheritance tax is not imposed at the federal level. However, states such as New South Wales and Victoria have minimal “probate fees” of less than 1%.
Austria
Austria abolished its inheritance tax in 2008.
Bahamas
The Bahamas does not have an inheritance tax, but it does have a real property tax that applies to inherited real estate. The tax rate ranges from 0.25% to 2%, depending on the value of the property.
Bangladesh
Bangladesh does not have an inheritance tax, but it does have a wealth tax that applies to estates with a net worth exceeding BDT 2.5 crore. The tax rate is 2.5%, and it is calculated based on the value of the estate minus any liabilities.
Belgium
In Belgium, inheritance tax is known as “successierechten” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 3% to 27%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was €50,000.
Brazil
In Brazil, inheritance tax is known as “imposto de transmissão causa mortis e doação” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries, as well as on gifts. The tax rate ranges from 4% to 8%, depending on the value of the asset or the estate. In 2021, the tax-free threshold for estates inherited by spouses and children was increased to R$ 5 million.
Canada
In Canada, inheritance tax is not imposed at the federal level, but some provinces have their own indirect estate taxes. For example, Quebec has a “succession duty” that applies to estates valued at more than $50,000, with a tax rate of up to 36% on the “capital gain” of the value of the properties being transferred assuming a fictitious sale. In Ontario, a minimal estate tax of 1-2% is due above estate values of $50,000. British Colombia charges a similarly minimal 1-2% on estates.
Chile
Chile has a progressive inheritance tax system that applies to both residents and non-residents who inherit assets located in Chile. The tax rate ranges from 1% to 25%, depending on the value of the estate and the relationship between the deceased and the beneficiary. Immediate family members are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was CLP 29.7 million.
China
There are no inheritance taxes in China.
Colombia
Colombia treats inheritances as extraordinary gains and taxes them at the capital gains tax rate of 15%.
Costa Rica
Costa Rica does not have inheritance taxes, however, the country taxes the transfer of real estate upon death at progressive rates ranging from 1-2%.
Croatia
Croatia has a progressive inheritance tax system that applies to both residents and non-residents who inherit assets located in Croatia. The tax rate ranges from 0.8% to 4%, depending on the value of the estate and the relationship between the deceased and the beneficiary. Immediate family members are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was HRK 10 million.
Cyprus
Cyprus abolished its inheritance tax in 2001, however, it does charge asset transfer “fees” (effectively taxes). These range from 4-8% and depend on the relationship between the involved individuals.
Czech Republic
The Czech Republic abolished inheritance taxes in 2013.
Denmark
Denmark has a flat-rate inheritance tax system that applies to both residents and non-residents who inherit assets located in Denmark. The tax rate is 15%, for spouses and children. An additional 25% is due for other relatives such as siblings. There is a tax-free threshold of DKK DKK 321,700 as of 2023. The inheritance tax must be paid within six months of the date of death, and failure to pay can result in interest and penalties.
Egypt
Egypt’s inheritance taxes were abolished in 1996.
France
In France, inheritance tax is known as “droits de succession” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 5% to 60%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. For example, spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals.
Germany
In Germany, inheritance tax is known as “Erbschaftsteuer” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 7% to 50%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by children was increased to €400,000. The tax-free threshold for spouses is €500,000.
Hong Kong (China)
In Hong Kong, inheritance tax is not imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. However, there is a tax on the transfer of real estate known as “stamp duty.” The stamp duty rate ranges from 1.5% to 8.5%, depending on the value of the property and the citizenship of the buyer. Hong Kong’s stamp duty changes regularly depending on the current performance of the property market.
India
India does not charge inheritance taxes, which were abolished in 1985.
Indonesia
In Indonesia, inheritance tax is known as “pajak warisan” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 1% to 10%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was IDR 10 billion.
Ireland
In Ireland, inheritance tax is known as “capital acquisitions tax” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate is 33%. Spouses do not have to pay any inheritance tax. Children are eligible for higher exemptions than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by children was €335,000.
Israel
Israel does not charge inheritance taxes.
Italy
In Italy, inheritance tax is known as “imposta sulle successioni” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 4% to 8%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was increased to €1 million.
Japan
In Japan, inheritance tax is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 10% to 55%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was increased to ¥150 million.
Malta
Malta has a flat-rate inheritance tax system that applies to both residents and non-residents who inherit assets located in Malta. The tax rate is 5%, and there is no exemption or threshold. However, spouses and children are eligible for a tax-free threshold of €1.5 million and €750,000, respectively. The inheritance tax must be paid within six months of the date of death, and failure to pay can result in interest and penalties.
Mexico
While Mexico does not have a general inheritance tax, it does charge non-citizen Mexican residents income tax on inherited property and shares located in the country.
Montenegro
Montenegro only taxes inherited real estate, at 3%. Exemptions are available for spouses and children.
Netherlands
In the Netherlands, inheritance tax is known as “erfbelasting” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 10% to 36%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses was €662,881 and for children €20,148.
New Zealand
In New Zealand, there are no inheritance taxes.
Nigeria
Nigeria does not have an inheritance tax, but it does have a capital gains tax that applies to the sale of inherited assets. Nigeria’s capital gains tax is 10% and the tax is calculated based on the difference between the sale price and the fair market value of the asset at the time of inheritance.
Pakistan
Pakistan does not have an inheritance tax, but it does have a capital gains tax that applies to the sale of inherited assets. The applicable capital gains and property transfer taxes vary by region.
Panama
Inheritance taxes were abolished in Panama in 2002.
(The) Philippines
In the Philippines, inheritance tax is known as “estate tax” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate is 6%. Spouses and children are eligible for higher exemptions than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was PHP 10 million.
Poland
Poland has a progressive inheritance tax system that applies to both residents and non-residents who inherit assets located in Poland. The tax rates range from 3% to 12% depending on who inherits the assets and how large the inheritance is. However, spouses and children are eligible for a tax-free threshold of PLN 9,637 and PLN 6,879, respectively. The inheritance tax must be paid within six months of the date of death, and failure to pay can result in interest and penalties.
Portugal
In Portugal, there are officially no inheritance taxes. However, a recipient of an inheritance has to pay a “transfer tax” known as “imposto sobre as sucessões e doações”. The tax rate is a flat 10%. The tax only applies to Portugal-based assets. In 2021, the tax-free threshold for estates inherited by spouses and children was €1 million.
Qatar
In Qatar, inheritance tax is not imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries.
Russia
Russian inheritance taxes were abolished in 2006.
Saudi Arabia
In Saudi Arabia, there is no inheritance tax.
Serbia
Serbia has a progressive inheritance tax system that applies to both residents and non-residents who inherit assets located in Serbia. The tax rate ranges from 1.5% to 2.5%, depending on the value of the estate and the relationship between the deceased and the beneficiary. Immediate family members are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In fact, first degree relatives are 100% exempt from inheritance taxes. In 2021, the tax-free threshold for estates inherited by spouses and children was RSD 4 million.
Singapore
In Singapore, inheritance tax is not imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. However, there is a tax on the transfer of real estate known as “stamp duty.” The stamp duty rate ranges from 1% to 4%, depending on the value of the property and the citizenship of the buyer.
South Africa
In South Africa, inheritance tax is known as “estate duty” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate is progressive and ranges from 20% to 25%, depending on the value of the estate. In 2021, the first R3.5 million of an individual’s estate is exempt from taxation. Married couples can combine their exemptions to double the tax-free amount to R7 million.
South Korea
In South Korea, inheritance tax is known as “gyejeolje” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 10% to 50%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was KRW 3 billion.
Spain
In Spain, inheritance tax is known as “impuesto sobre sucesiones y donaciones” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries, as well as on gifts. The tax rate ranges from 7.65% to 34%, depending on the value of the asset or the estate and the relationship between the deceased and the beneficiaries. Taxes also vary by commune. In 2021, the tax-free threshold for estates inherited by spouses and children was increased to €1 million.
Sweden
Sweden is one of the only European Union member countries that does not charge any inheritance taxes, which were abolished back in 2005.
Switzerland
In Switzerland, inheritance tax is not imposed at the federal level, but cantons have their own estate taxes. Generally speaking, there are never inheritance taxes on assets inherited by spouses. Similarly, rarely do children have to pay inheritance taxes. Siblings and non-relatives pay inheritance taxes up to 45% in some cantons, with minimal exemption amounts of just 10,000-20,000CHF.
Taiwan (China)
Taiwan has a progressive inheritance tax system that applies to both residents and non-residents who inherit assets located in Taiwan. The tax rate ranges from 10% to 20%, depending on the value of the estate and the relationship between the deceased and the beneficiary. Immediate family members are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was TWD 20 million.
Thailand
In Thailand, inheritance tax is known as “sor chor 2” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate is 5% for direct descendants and parents, and 10% in all other cases. In 2021, the tax-free threshold for estates inherited by spouses and children was THB 100 million.
Turkey
In Turkey, inheritance tax is known as “veraset ve intikal vergisi” and is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate ranges from 1% to 30%, depending on the value of the estate and the relationship between the deceased and the beneficiaries. Spouses and children are eligible for higher exemptions and lower tax rates than more distant relatives or unrelated individuals. In 2021, the tax-free threshold for estates inherited by spouses and children was TRY 5 million.
United Arab Emirates
The United Arab Emirates (UAE) does not impose any inheritance or estate taxes. However, non-muslims should set up a proper local will to avoid Shariah law.
United Kingdom
In the United Kingdom, inheritance tax is imposed on the transfer of assets from a deceased individual to their heirs or beneficiaries. The tax rate is 40% and is applied to estates with a value over £325,000. Married couples and civil partners can combine their exemptions to double the threshold to £650,000. There are also some additional exemptions available, such as a nil-rate band for the family home worth up to £175,000 per person.
United States
The United States has a federal estate tax that applies to the transfer of property from a deceased individual to their heirs or beneficiaries. The tax rate is progressive and ranges from 18% to 40%, depending on the value of the estate. In 2021, for US residents, the first $11.7 million of an individual’s estate is exempt from taxation, while married couples can combine their exemptions to double the tax-free amount to $23.4 million. The tax is paid by the estate before the assets are distributed to the heirs or beneficiaries.
A smaller exemption amount of $60,000 applies to US assets owned by non-US residents.
Some states in the US also impose their own estate or inheritance taxes, which can add to the total tax burden on an estate. However, many states have either abolished their estate taxes or have exemptions that match the federal exemption amount.
Conclusion
As demonstrated in this article, the inheritance tax laws of each country can vary significantly. While some countries have a flat-rate inheritance tax system with no exemptions or thresholds, others have a progressive system that offers tax-free thresholds for immediate family members. Some countries have no inheritance tax at all but may have other taxes that apply to inherited assets.
Many countries offer exemptions or lower tax rates for immediate family members, which can significantly reduce the tax burden on inheritances. Some countries, like the United States and Canada, have high tax rates and relatively low exemptions, while others, like Hong Kong and New Zealand, do not have inheritance tax but impose stamp duty on the transfer of real estate.
If you are planning your estate, it’s important to consult with a tax professional who is knowledgeable about the laws of your country and can help you minimize the tax burden on your heirs. By carefully planning your estate, you can ensure that your assets are distributed according to your wishes and that your heirs are not burdened with an excessive tax bill.
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