Inheritance Tax by Country: Global Rates Comparison 2026

Inheritance tax (IHT) — also called estate tax or succession tax depending on the country — 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 — and how to plan around them — 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:

Major Economy Inheritance Tax Rates

United Kingdom

• Rate: 40% on net estate above the threshold
• Nil-Rate Band: £325,000 per person (frozen until 2028)
• Residence Nil-Rate Band: Additional £175,000 when passing a residence to direct descendants
• Couple's Combined Allowance: Up to £1,000,000 (£325,000 + £175,000 × 2) when both allowances are transferred to surviving spouse
• Spouse Exemption: 100% exempt — transfers between UK-domiciled spouses are unlimited
• Business/Agricultural Relief: 100% or 50% relief for qualifying business assets (reduced from April 2026 — see Budget 2024 changes)

United States

• Federal Rate: 40% on taxable estate
• Exemption (2026): $15 million per individual (OBBBA raised exemption and made it permanent — TCJA sunset repealed)
• Unlimited Marital Deduction: Assets passed to US citizen spouse are 100% exempt
• Portability: Unused exemption of deceased spouse can be transferred to surviving spouse
• State Estate Tax: 12 states + DC have estate/inheritance taxes (Washington: $3M exclusion, 20% top rate above $9M; Oregon: 16% above $1M)

Germany

• Rates: 7–30% for direct family (Class I); 15–43% for siblings/nieces/nephews (Class II); 30–50% for others (Class III)
• Exemptions: Spouse: €500,000; Children: €400,000 per child (every 10 years); Grandchildren: €200,000; Siblings: €20,000
• Special: Business assets may qualify for 85–100% exemption (Betriebsvermögen) if business is retained

Japan

• Rates: Progressive 10–55% (highest in the world)
• Basic Deduction: ¥30M + ¥6M per legal heir
• Spouse Deduction: Larger of ¥160M or the spouse's legal share (often effectively 0% for surviving spouse)
• Key issue for expats: Japan taxes worldwide assets for residents and has a 10-year lookback for former residents who were Japanese nationals

France

• Rates: 5–45% for direct heirs (children); 35–45% for siblings; 55–60% for non-relatives
• Allowances: €100,000 per child (every 15 years); €80,724 for spouse
• Life Insurance: Policies written before age 70 with separate beneficiaries can pass €152,500 per beneficiary tax-free outside the estate

Cross-Border Inheritance Tax Considerations

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

• Domicile vs Residency: UK IHT applies based on domicile (not just residency) — a UK-domiciled person's worldwide assets are subject to UK IHT even if they live abroad
• Double Tax Treaties: The US has estate tax treaties with 15 countries (UK, France, Germany, Canada, Australia, Netherlands, Japan, and others) preventing full double taxation
• US Estate Tax for Non-Residents: Non-US-domiciled individuals with US situs assets (US stocks, US real estate) face US estate tax on those assets above just $60,000 (vs $15M for US domiciliaries)
• Japan's 10-Year Rule: Japanese nationals who emigrate remain subject to Japan's worldwide IHT for 10 years after departure — a critical planning consideration for high-net-worth Japanese nationals relocating
• Germany's 10-Year Rule: German nationals who move abroad remain subject to unlimited German IHT for 5 years (not 10); domicile issues are complex