Inheritance and estate taxes vary dramatically by country. The US federal estate tax exemption is $13.61 million per person (2024), with a top rate of 40%. The UK charges Inheritance Tax at 40% above £325,000. Many countries — including Australia, Canada, New Zealand, and Singapore — have no inheritance tax at all. Use the guides below to find the rules for your jurisdiction.
At a glance
Key Facts
Inheritance Tax vs Estate Tax — The Difference
An estate tax is levied on the total value of a deceased person's estate before distribution. An inheritance tax is levied on the beneficiary based on what they receive. The US and UK use estate-side taxes (though the UK calls it Inheritance Tax, it is assessed on the estate, not the recipient). Some European countries (Germany, Belgium, France) levy inheritance taxes on beneficiaries, with rates varying by relationship to the deceased.
The US Estate Tax Exemption Cliff (2026)
The Tax Cuts and Jobs Act (TCJA) doubled the US federal estate tax exemption. The current exemption is $13.61 million per person ($27.22 million for married couples) in 2024, indexed for inflation to approximately $13.99 million in 2025. Unless Congress acts, this exemption reverts to approximately $7 million (inflation-adjusted) on 1 January 2026. Estates above the post-reversion threshold face a top federal estate tax rate of 40%. This cliff affects planning decisions made in 2025 and early 2026.
Countries With No Inheritance or Estate Tax
A large number of developed economies have abolished inheritance and estate taxes: Australia (abolished 1979), Canada (no federal estate tax; provincial probate fees apply), New Zealand (no estate or inheritance tax), Singapore (abolished 2008), Sweden (abolished 2004), Norway (abolished 2014), Portugal (only applies to non-direct-line beneficiaries), and many others. Some jurisdictions abolished these taxes for competitiveness reasons — though many debate whether they should be reintroduced.
UK Inheritance Tax and the £325,000 Nil-Rate Band
UK Inheritance Tax (IHT) is charged at 40% on the value of an estate above the £325,000 nil-rate band (NRB). An additional £175,000 residence nil-rate band (RNRB) applies when a main residence passes to direct descendants. Combined, a married couple can currently pass £1 million free of IHT using both nil-rate bands. The standard 40% rate applies on amounts above the threshold, with a reduced 36% rate if at least 10% of the estate is left to charity.
Introduction
Inheritance tax, estate tax, and wealth tax are among the most misunderstood areas of international tax planning — partly because the rules vary so dramatically by country, and partly because the consequences of getting them wrong affect not just the individual but their beneficiaries.
This hub aggregates every inheritance, estate, and wealth tax guide on CountryTaxCalc, organised by scope. Whether you need to understand the US estate tax exemption cliff in 2026, the UK IHT nil-rate band, countries with no inheritance tax, or how international estates are taxed across borders, the guides below are sourced from official government tax authorities and reviewed annually.
Important: Inheritance, estate, and wealth tax planning is YMYL (Your Money or Your Life) territory — mistakes can cost families significant sums. The guides on this site provide verified reference information from official sources. For personal planning involving significant assets, always consult a qualified estate planning attorney or tax adviser.
Section 01
Global Inheritance & Estate Tax Comparisons
These guides compare inheritance and estate tax rates across countries — essential reading before making cross-border estate planning decisions or before moving assets or residency internationally.
Inheritance Tax: USA vs Europe 2026 — estate tax exemptions, rates, and who actually pays inheritance tax compared between the US and major European systems
Section 02
US Estate Tax Guides
The US federal estate tax affects only the wealthiest estates — but the 2026 exemption reduction (the 'TCJA cliff') means significantly more estates will be affected unless Congress extends the current thresholds. State-level estate taxes add additional complexity in several states.
CountryTaxCalc.com is reader-supported. When you use our partner links, we may earn a commission at no cost to you. This helps us provide free tax calculators and comparison tools. Learn more about our affiliate partnerships
US Expat Tax Specialist
Greenback Expat Tax Services
★ 4.8 Trustpilot · 1,625 reviews
US citizens abroad face US estate tax obligations on worldwide assets regardless of where they live. Greenback's CPAs handle cross-border estate tax filings, FBAR for inherited foreign accounts, and expatriate estate planning.
⚠ Not the cheapest option — best for complex situations and expats who want a dedicated CPA.
Receiving an inheritance from abroad or transferring inherited assets across borders? Wise handles international transfers in 40+ currencies at the mid-market rate — no hidden fees on large transfers.
⚠ For currency exchange only — not a bank account replacement.
The US does not have a federal inheritance tax — it has a federal estate tax, which is levied on the estate itself before assets are distributed to beneficiaries. However, six US states do impose a state-level inheritance tax: Iowa (being phased out), Kentucky, Maryland, Nebraska, New Jersey, and Pennsylvania. Maryland also has a state estate tax in addition to an inheritance tax — making it one of the most complex states for estate planning. The federal estate tax currently applies at 40% on taxable estates above approximately $13.61 million (2024 figure).
Q
What is the UK Inheritance Tax rate and threshold?
UK Inheritance Tax (IHT) is charged at 40% on the value of an estate above the nil-rate band (NRB) of £325,000. An additional residence nil-rate band (RNRB) of £175,000 applies when a main home is left to direct descendants (children or grandchildren). Married couples and civil partners can combine their allowances, potentially allowing £1 million to pass tax-free. A reduced IHT rate of 36% applies when 10% or more of the net estate is left to a UK charity. The UK government has announced that inherited pension pots will be included in IHT calculations from April 2027 — a significant change for those planning pension wealth transfers.
Q
Which countries have completely abolished inheritance and estate tax?
Countries with no inheritance, estate, or gift tax on inherited wealth include: Australia, Canada (probate fees apply in some provinces), New Zealand, Singapore, Sweden, Norway, Russia, India, and China. The full list — with important caveats about what taxes do apply (capital gains on sale of inherited assets, for example) — is covered in the Countries with No Inheritance Tax 2026 guide.
Q
Is inheritance taxable income in the US?
In general, inherited assets are not considered taxable income at the federal level — the estate tax is paid by the estate before distribution, so beneficiaries typically receive assets free of additional income tax. However, income generated by inherited assets after transfer (dividends, rent, interest) is taxable as ordinary income. Inherited retirement accounts (IRAs, 401Ks) follow specific Required Minimum Distribution rules that may generate taxable distributions. The step-up in basis rule is critical: most inherited assets receive a cost basis 'stepped up' to the fair market value at the date of death, eliminating any embedded capital gains tax on pre-death appreciation.
Q
What is a wealth tax and which countries have one?
A wealth tax is an annual levy on a person's total net wealth above a threshold — distinct from income tax (which taxes earnings) and inheritance tax (which taxes transfers at death). Few countries currently have a broad annual wealth tax: Norway charges 1.1% on net wealth above NOK 1.7 million (approximately $160,000); Switzerland levies cantonal wealth taxes ranging from 0.1% to 1%; Spain has a wealth tax of up to 3.5% on net assets above €700,000 (varies by region). France abolished its broad wealth tax (ISF) in 2017, replacing it with a more limited real estate wealth tax (IFI). The Netherlands taxes a deemed return on assets (Box 3), which functions similarly to a wealth tax.
Q
What is the US estate tax exemption in 2026?
The US federal estate tax exemption in 2024 is $13.61 million per individual ($27.22 million for a married couple using portability). The exemption is adjusted for inflation annually. Under current law, the Tax Cuts and Jobs Act (TCJA) provisions expire on 31 December 2025, causing the exemption to roughly halve to approximately $7 million (inflation-adjusted) from 1 January 2026. If Congress does not extend the TCJA provisions, estates between approximately $7 million and $13.61 million that were previously below the exemption threshold may become subject to estate tax at up to 40%. Estate planning completed before the year-end deadline may be particularly valuable for affected estates.
Q
Do I pay inheritance tax on foreign assets I inherit?
This depends on your country of residence, the deceased's country of domicile, and whether a tax treaty exists between the two countries. UK IHT applies to assets of UK-domiciled individuals worldwide and to UK-situated assets regardless of the owner's domicile — meaning a non-UK resident can face UK IHT on UK property. US estate tax applies to US-situated assets of non-US persons and to worldwide assets of US citizens and US-domiciled residents regardless of where they live. Many countries have estate and succession tax treaties that prevent double taxation. For cross-border estates, specialist international estate planning advice is essential.
Disclaimer:Inheritance tax, estate tax, and wealth tax rules are subject to frequent legislative change. The figures and thresholds in the linked guides are sourced from official government tax authorities and are accurate at the date shown on each guide. Tax laws in this area are complex, jurisdiction-specific, and can interact across borders in ways that are not captured by general guides. This hub provides verified reference information for educational purposes only — it is not legal, financial, or estate planning advice. For personal situations involving significant assets or cross-border estates, always consult a qualified estate planning attorney and a tax adviser licensed in the relevant jurisdictions.