An estate holding US shares, a London flat and a Singapore account answers to at least three legal systems at once. The first planning question is which tax model the family falls under, and which assets stick to a foreign jurisdiction regardless of where the owner lives. The spread is wide: above the threshold London takes 40%, Paris takes 60% from an unrelated heir, Moscow and Singapore take nothing.
Every rate and threshold below is taken from primary sources — HMRC, IRS, Service-Public, BOE, ErbStG, Agenzia delle Entrate — and stands as of 2026. Each jurisdiction is shown with its nexus: whom it taxes and on what.
Concept
The world's regimes reduce to four models. Estate tax charges the estate itself before distribution: the United States and the United Kingdom both work this way, both at 40%. Inheritance tax charges each heir on their own share, with rates climbing as kinship weakens: France, Germany, Spain, Italy — and the record holders Japan (up to 55%) and South Korea (50%). On OECD figures only 24 of the organisation's 38 members levy an inheritance or estate tax, raising on average about 0.5% of total tax revenue.
The third model is deemed disposal: no inheritance tax at all, but death counts as a realisation, and Canada charges capital gains in the deceased's final return. The fourth is zero: Russia, the UAE, Singapore and Hong Kong, where estate duty was repealed, Australia with its cost-base rollover to the beneficiary, Sweden and Austria, which dropped the tax in 2005 and 2008. Zero almost always carries an asterisk — the deferred charge surfaces when the inherited asset is sold.
Three nexus tests decide who is caught. Personal: the US ties the tax to citizenship and green-card status, the UK to long-term residence, while Germany and Spain look at the heir's residence too. Objective — situs: local real estate and shares in local companies are taxed by their home country whatever the owner's residence. Treaty: estate tax treaties are rare, so claims from two countries often stack with no mutual credit.
Criteria for Comparison
A decision for a specific family assembles from five parameters:
- taxpayer: the estate as a whole, or each heir separately;
- nexus: citizenship or residence of the deceased, residence of the heir, situs of the assets;
- progression: by size of the estate (US, UK) or by degree of kinship (continental Europe);
- allowances: from the $15M US exclusion to no relief at all for unrelated heirs in Spain;
- reach over non-residents: what the country treats as its own asset.
Those same parameters form the columns of the map.
Jurisdiction Map — 2026
All figures stand as of 2026; each jurisdiction is shown with its model, rates, allowances and nexus.
| Jurisdiction | Model | Rates 2026 | Allowances | Nexus and reach over non-residents |
|---|---|---|---|---|
| United States | estate tax | up to 40% | $15M — citizens and residents (OBBBA); portability between spouses | citizenship and green card — worldwide; non-residents — US-situs assets above $60,000 |
| United Kingdom | estate model (IHT) | 40% | nil-rate band £325,000 (to 5 Apr 2031) + £175,000 residence band (to 5 Apr 2030); spouse exempt | long-term resident (10 of the last 20 years) — worldwide, 3–10 year tail after departure; UK assets — always |
| France | tax on the heir | direct line 5–45%; siblings 35–45%; to the 4th degree 55%; unrelated 60% | €100,000 per child; spouse and PACS partner fully exempt | French assets — always; residence of the deceased or the heir extends it worldwide |
| Germany | tax on the heir | classes I–III: 7–30% / 15–43% / 30–50% | spouse €500,000; child €400,000; grandchild €200,000; classes II–III €20,000 | residence of the deceased or the heir — worldwide; German assets — always |
| Spain | tax on the heir | state scale 7.65–34% × coefficient 1.0–2.4 | Group II — €15,956.87 under the state scale; autonomous communities add their own relief | resident heir — worldwide; non-residents — Spanish assets |
| Italy | tax on the heir | 4% / 6% / 8% | €1M franchise — spouse and direct line; €100,000 — siblings | resident deceased — worldwide; otherwise Italian assets |
| Switzerland | cantonal taxes | spouse — 0 almost everywhere; descendants — 0 in most cantons; meaningful rates for unrelated heirs | set by canton | residence of the deceased in the canton; local real estate |
| Russia | no tax (since 2006) | 0 on receipt (art. 217(18) Tax Code) | — | income tax on sale within three years of ownership |
| Canada | deemed disposition | capital gains — in the deceased's final return | rollover to a surviving spouse | worldwide assets of a Canadian resident |
| Australia | no tax | 0; CGT when the beneficiary sells | cost-base rollover | — |
| Singapore / Hong Kong | no tax | estate duty repealed (2008 / 2006) | — | — |
Comparing headline rates alone misleads: the US 40% starts at $60,000 for a non-resident, the Spanish 34% multiplied by the 2.4 coefficient reaches a theoretical 81.6% for a wealthy unrelated heir, and the Canadian zero turns into tax on every dollar of accrued capital gain.
Estate Tax: The US and the UK
The US taxes the estate on a progressive scale topping out at 40%, but the exclusion for citizens and residents is $15 million per person in 2026: OBBBA fixed that level and indexation continues from there, with the unused portion portable to a surviving spouse.
The regime carries a second benefit — the basis step-up: the heir takes the asset at its date-of-death market value and the gain accrued during life escapes income tax, a mechanism covered in the article on basis step-up. For non-residents the terms invert: US-situs assets — US real estate, tangible property in the US, stock of corporations organised under US law — are taxed above a $60,000 threshold on Form 706-NA; the detail and the workarounds sit in the piece on US estate tax.
The UK charges 40% above a nil-rate band of £325,000; a home passing to children or grandchildren adds the £175,000 residence nil-rate band. The main band is fixed to 5 April 2031, the residence band to 5 April 2030. Since 6 April 2025 scope turns on residence: a long-term UK resident — tax resident in 10 of the previous 20 years — pays IHT on worldwide assets, and after departure the status persists a further 3 to 10 years depending on how long the residence lasted. What this changed for former non-doms is covered in the analysis of the 2025 reform, including the former deemed domicile test; UK assets stay in scope under any status.
Tax on the Heir: France, Germany, Spain, Italy
France: the direct line runs on a 5–45% scale with the top band above €1,805,677 per heir, siblings pay 35–45%, relatives to the fourth degree 55%, unrelated beneficiaries 60%. The abattement per child is €100,000; a surviving spouse and a PACS partner are fully exempt. An unmarried partner outside PACS counts as unrelated for tax: the same 60%.
Germany (ErbStG): class I — spouse, children, grandchildren — pays 7–30%; class II — siblings, nieces and nephews — 15–43%; class III — everyone else — 30–50%. The §16 Freibeträge are €500,000 for a spouse, €400,000 per child, €200,000 per grandchild and €20,000 for classes II and III. Liability arises where either the deceased or the heir is resident in Germany: one child moving to Munich pulls that child's share of the worldwide estate into German tax.
Spain: the 7.65–34% state scale is multiplied by a coefficient of 1.0 to 2.4 driven by kinship group and the heir's own pre-existing wealth. The state reduction for Group II (spouse, children over 21) is a modest €15,956.87, but autonomous communities may legislate their own scales and bonificaciones: in Madrid and Andalusia close relatives pay token amounts, elsewhere the charge is real. Who inherits, and in what order, under Spanish law is set out in the article on Spanish intestate succession.
Italy runs the mildest regime of the group: 4% for a spouse and the direct line with a €1M franchise per beneficiary, 6% for siblings (€100,000 franchise) and for relatives to the fourth degree, 8% for everyone else.
Zero With an Asterisk: Russia, Canada, Australia, Asia
Russia repealed its inheritance tax in 2006: receiving property is exempt from personal income tax whatever the kinship (art. 217(18) of the Tax Code; the exception is royalties paid to an author's heirs). The charge appears on sale: the minimum holding period for inherited property is three years, and a resident selling earlier pays income tax at 13% (15% above a ₽2.4M base), reduced by the deceased's documented acquisition costs. Statutory order and forced shares are covered in the article on Russian intestate succession.
Canada: no inheritance tax, but death is a deemed disposition — the deceased is treated as having sold capital property at market value immediately before death, with the gain reported in the final return; a transfer to a surviving spouse defers the charge. Australia abolished death duties outright: CGT arises only when the beneficiary disposes of the asset, and the cost base rolls over. Singapore and Hong Kong removed estate duty (15 February 2008 and 11 February 2006) — both hubs are neutral to the owner's death. Swiss tax is cantonal: spouses are exempt almost everywhere, direct descendants in most cantons, with meaningful rates left for distant relatives and unrelated heirs.
Situs Traps
The most common: US securities held by a non-resident. Apple shares in a Swiss or Singapore brokerage account remain US-situs — the location of the account is irrelevant, the threshold is $60,000 and rates run to 40%. Market exposure is preserved by switching into non-US UCITS funds or by wrapping the holding in an insurance policy; how situs is determined for shares, accounts and gold is covered in the article on movable asset situs.
The second: UK residential property held through an offshore company. Since 6 April 2017 shares in offshore close companies deriving their value from UK residential property have ceased to be excluded property (F(No. 2)A 2017, Sch 10) — IHT reaches through the holding structure, and the wrapper company pays ATED annually. A structure that sheltered London houses for decades now generates cost without protection; the regimes for foreign property are set out in the article on foreign real estate succession.
The third: double taxation. Estate tax treaties are far scarcer than ordinary income tax treaties — the US has around fifteen, most countries a handful. Without one, relief falls back on whatever unilateral credit domestic law provides, which rarely covers everything. Assets in several countries call for coordinated wills drafted for each jurisdiction.
What Actually Works
Lifetime gifts. In the UK a gift falls out of the estate after seven years; between years three and seven the tax on large gifts tapers through 32%, 24%, 16%, 8%, with a £3,000 annual exemption. In the US the annual exclusion is $19,000 per recipient (2026) and $194,000 for a non-citizen spouse; gifts beyond the exclusions draw down the same $15M unified credit that covers the estate. Germany refreshes its §16 allowances every ten years, so €400,000 per child can be used several times in a lifetime. In France a gift drops out of the estate calculation after fifteen years. Country regimes are compared in the article on lifetime gifting.
Trusts and foundations. Moving assets into a trust changes the owner before situs and residence can bite; UK trusts carry their own IHT regime with an entry charge and ten-year anniversary charges, covered in the article on trusts and inheritance tax. American families lock the $15M exclusion into dynasty trusts spanning generations; the continental alternative is a private foundation.
Insurance wrappers. A policy on the deceased's life passes outside the estate or on preferential terms in many regimes, and PPLI changes the nature of the asset itself: what passes is an insurance contract with its own situs and tax treatment rather than a securities portfolio.
Changing the nexus. Leaving the UK before long-term resident status accrues — or sitting out the 3–10 year tail — switches off worldwide IHT; the US perimeter holds as long as citizenship or a green card does, and no relocation removes it. The heir's residence counts alongside the deceased's: while the children remain resident in Germany or Spain, their shares are taxed there whatever the planning. The full sequence of decisions, from the asset inventory to the wills, is assembled in the succession navigator.
Risks
Five mistakes recur in cross-border estates more than any others.
Q/A
My US shares sit in a European broker's account. Can the US still charge estate tax?
Yes. Stock of a US-incorporated company stays US-situs wherever the account is held: a non-resident decedent with no treaty gets a threshold of only USD 60,000 before rates reaching 40%. The USD 15 million exclusion belongs to citizens and residents. Switching into non-US UCITS funds or wrapping the holding in a policy during life is what removes it from scope.
I have left the UK. When does worldwide IHT stop reaching me?
Long-term resident status persists for three to ten years after departure: the longer the residence lasted, the longer the tail. Twenty years of residence means a full decade of worldwide IHT after leaving; UK-situs assets stay in scope regardless.
Our assets sit in countries with no inheritance tax. Will the heirs really pay nothing?
There is no guarantee — the charge often hides in another regime. Canada taxes accrued gain in the deceased's final return, Australia rolls the cost base over and waits for the sale, Russia charges income tax when inherited property is sold within three years. Every zero row on the map should be checked for a realisation charge.
Two countries are claiming the same estate. Can one tax be credited against the other?
By treaty, rarely: estate tax treaties are scarce, the US has around fifteen and most countries fewer. What remains is the unilateral credit of the country of residence, which covers neither every asset nor the whole amount. Arranging situs during life so that only one claim arises is the more reliable route.
I am leaving everything to a nephew and to an unmarried partner. How much more does that cost?
In continental Europe, several times over. France charges a nephew 55% and an unrelated partner 60%; Germany puts both in classes II–III at 15–50% with a €20,000 allowance; Spain adds its multiplier on top of the scale. Marriage, PACS, adoption or an insurance structure changes the kinship group — and the rate with it.