Concept
Inheritance tax is one of the most uneven taxes in the world: in some places it reaches 40–55%, while in others it doesn't exist at all. For families with international assets, this is not an abstraction but a question of geography: where to hold capital and through what structure.
🍓 In the US and UK, inheritance tax runs up to 40%; in France and Spain it's progressive; while in Russia, the UAE, and a number of countries it doesn't exist. Asset geography matters more than it seems.
High-Tax Countries
USA (estate tax up to 40%, with only a $60,000 exemption for non-residents), United Kingdom (IHT 40% above £325,000), France, Germany, Spain, Japan (up to 55%)—here inheritance tax is a serious factor. In France and Spain the rate is progressive and depends on the degree of relationship: the more distant the relative, the more they pay.
Countries Without Inheritance Tax
Russia (inheritance tax was abolished back in 2006), UAE, many offshore jurisdictions, and also under certain conditions Canada and Australia (no inheritance tax, but there is a "death tax" through capital gains). "No tax" doesn't always mean "no consequences": instead of inheritance tax there may be capital gains tax.
⚙️ It matters not only where the decedent lived, but also where the assets are located: inheritance tax is often tied to the situs of property, so real estate in France pays French tax regardless of the owner's residence.
What This Means for Planning
🔗 Related
US estate tax and US-situs · US Estate Tax · Trusts and Inheritance Tax (UK) · Gift Tax · Foreign Real Estate Succession
The tax map determines where it makes sense to hold assets and what structures to use. Real estate in high-tax countries is often held through a company; US stocks are moved out of US-situs; for UK-connected families, residence-based IHT is calculated. This is work across all countries at once.
💡 The most treacherous case is the US: see US estate tax and US-situs.
This material is for reference purposes and does not constitute individual legal advice.
Key factual claims
- Inheritance tax is one of the most uneven taxes in the world: in some places it reaches 40–55%, while in others it doesn't exist at all.
- USA (estate tax up to 40%, with only a $60,000 exemption for non-residents), United Kingdom (IHT 40% above £325,000), France, Germany, Spain, Japan (up to 55%)—here inheritance tax is a serious factor.
- Russia (inheritance tax was abolished back in 2006), UAE, many offshore jurisdictions, and also under certain conditions Canada and Australia (no inheritance tax, but there is a "death tax" through capital gains).