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Inheritance Tax by Country: Global Rates Comparison 2026

Quick Answer: Countries with no inheritance tax include: Australia, Canada, New Zealand, Sweden, Norway, Portugal, Israel, Singapore, UAE. Highest inheritance tax rates: Japan (55%), South Korea (50%), France (45%), UK (40%), USA (federal 40% on estates above $13.6M). Germany charges 7–50% depending on relationship.
By CountryTaxCalc Research Team

Last Updated: April 2026

Key Facts

Highest Inheritance Tax
Japan 55%, South Korea 50%, France 45%, UK 40%, USA 40% (federal)
No Inheritance Tax
Australia, Canada, New Zealand, Sweden, Norway, Finland (abolished), Portugal, Israel, Singapore, UAE, Hong Kong
UK Threshold
Β£325,000 nil-rate band + Β£175,000 residence nil-rate band; 40% above; spouse transfer 100% exempt
US Threshold
$13.61M (2024) federal exemption; 40% above; unlimited marital deduction
Germany
€500,000 exemption for spouses; €400,000 for children; 7–30% for direct family; 15–50% for others

Inheritance tax (IHT) β€” also called estate tax or succession tax depending on the country β€” is levied on assets transferred at death. Rates range from 0% (Australia, Canada, Sweden) to 55% (Japan). For high-net-worth families with assets in multiple countries, understanding which countries' inheritance taxes apply β€” and how to plan around them β€” can mean preserving millions of dollars for heirs.

This guide covers inheritance tax rates in major economies, key exemptions (particularly for spouses and children), cross-border estate planning considerations, and the list of countries that have abolished inheritance tax entirely.

Countries With No Inheritance Tax

These countries have either abolished inheritance tax or never had one:

CountryStatusYear Abolished (if applicable)
AustraliaNo inheritance taxAbolished 1979
CanadaNo inheritance taxAbolished 1972 (deemed disposal CGT applies at death)
New ZealandNo inheritance taxAbolished 1992
SwedenNo inheritance taxAbolished 2004
NorwayNo inheritance taxAbolished 2014
PortugalNo inheritance tax (direct family)Direct heirs exempt; 10% stamp duty on non-direct heirs
SingaporeNo estate dutyAbolished 2008
UAENo inheritance taxNever introduced
Hong KongNo estate dutyAbolished 2006
IsraelNo inheritance taxAbolished 1981
ChinaNo inheritance taxNever introduced at national level
IndiaNo inheritance taxAbolished 1985

Major Economy Inheritance Tax Rates

United Kingdom

United States

Germany

Japan

France

Cross-Border Inheritance Tax Considerations

When a deceased person has assets or heirs in multiple countries, inheritance tax can become complex:

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Frequently Asked Questions

Q: Why did so many countries abolish inheritance tax?

Inheritance tax has been abolished in many countries over the past 50 years due to several converging arguments: (1) Double taxation β€” assets have often already been taxed as income, capital gains, or corporate profits during the owner's lifetime; (2) Economic efficiency β€” IHT can force the sale of family businesses and farms that are asset-rich but cash-poor; (3) Political unpopularity β€” surveys consistently show inheritance tax is among the least popular taxes even with voters who will never pay it; (4) Avoidance β€” sophisticated estates can typically structure around IHT with trusts and gifting strategies, meaning IHT often falls disproportionately on middle-class families rather than the super-wealthy; (5) Capital flight β€” countries that retain IHT (France, UK, Japan) face pressure from wealthy individuals relocating to no-IHT jurisdictions. Sweden abolished IHT in 2004; Norway in 2014 β€” both finding the economic costs outweighed the revenue.

Q: Is there inheritance tax in Australia?

No β€” Australia abolished all state inheritance and death duties by 1981, and has no federal inheritance tax. However, inherited assets in Australia are subject to capital gains tax when eventually sold. The CGT calculation uses the cost base at the time of inheritance (not the original purchase price), so most inherited assets have a low CGT liability unless significantly appreciated after inheritance. Superannuation (pension) accounts have special tax treatment on death: death benefits paid to dependants (spouse, minor children) can be tax-free; benefits paid to non-dependants (adult children) are taxed at 15–30% depending on the components.

Q: What is the UK inheritance tax nil-rate band and how does it work?

The UK nil-rate band (NRB) is Β£325,000 β€” the amount below which no UK inheritance tax is charged (40% applies above this). There is also a residence nil-rate band (RNRB) of Β£175,000 when the deceased's main residence is left to direct descendants (children, grandchildren). Combined, a single person can pass Β£500,000 tax-free. For married couples: when the first spouse dies leaving everything to the surviving spouse (exempt from IHT), the unused NRB is transferred to the survivor. This means a surviving spouse can have up to Β£1,000,000 combined (Β£325,000 + Β£175,000 Γ— 2) before IHT applies. Both nil-rate bands are frozen until at least 2028, which means more estates are gradually being pulled into IHT as property values rise β€” fiscal drag is increasing the effective IHT burden without any rate change.

Q: How can I reduce my UK inheritance tax liability?

Common UK IHT reduction strategies: (1) Annual gifting β€” Β£3,000/year can be given away tax-free; potentially exempt transfers (PETs) become exempt if the donor survives 7 years; (2) Spouse/civil partner transfers β€” unlimited IHT-exempt transfers between UK-domiciled spouses; (3) Business Property Relief β€” qualifying business assets receive 100% relief (though Budget 2024 capped BPR at Β£1M from April 2026); (4) Agricultural Property Relief β€” 100% on qualifying agricultural land; (5) Charitable giving β€” gifts to charity are exempt; leaving 10%+ of estate to charity reduces estate IHT rate from 40% to 36%; (6) Trusts β€” discretionary trusts can hold assets outside the estate (complex rules apply); (7) Life insurance β€” whole-of-life insurance written in trust can provide funds to pay the IHT bill without adding to the estate. Always get professional advice β€” IHT planning is one of the most complex areas of UK tax.

Q: Does Canada have inheritance tax?

Canada has no inheritance tax per se β€” there is no tax charged on the receipt of inherited assets. However, Canada has a 'deemed disposition' rule at death: the deceased person is treated as having sold all their assets at fair market value immediately before death, triggering capital gains tax at that point (at 50% inclusion for gains up to $250,000, or 66.67% above that). This CGT is the estate's tax liability, not the beneficiary's. Registered accounts (RRSP, RRIF) are included in the deceased's income in the year of death unless transferred to a qualifying spouse or dependent. In practice, for most Canadians, the deemed disposition CGT on death is far less burdensome than a UK-style IHT, particularly since the principal residence exemption eliminates CGT on the family home.

Disclaimer: This guide provides general tax information for educational purposes only. Inheritance and estate tax laws are complex, jurisdiction-specific, and change frequently β€” notably, UK Budget 2024 made significant changes to Business Property Relief and Agricultural Property Relief effective April 2026. Always consult a qualified estate planning professional before making decisions.

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