Updated 25 October 2026

Inheritance Tax by Country 2026: Thresholds, Rates and Who Pays

Quick answer: Japan has the highest inheritance tax rate in the world, up to 55%, followed by South Korea (50%), France (45% for children), the United Kingdom and the United States (both 40%). But rates tell only half the story, because tax-free allowances differ enormously. The US taxes only estates above $15 million per person from 2026, so almost no American families pay federal estate tax, while the UK taxes estates above £325,000 (£500,000 if a home goes to children, and up to £1 million for a married couple). Germany lets each child inherit €400,000 tax-free, Ireland €420,000 and Italy €1 million. Many countries have no inheritance tax at all, including Canada, Australia, New Zealand, Sweden, Norway, Austria, India, China, Mexico, Singapore, Hong Kong and the UAE, although some, such as Canada, tax capital gains at death instead. Spouses are exempt in most countries. The interactive table below compares 28 countries.

Inheritance tax rules are scattered across national tax authorities, change often, and are rarely explained side by side. This guide brings together the main rules for 2026 for children inheriting from a parent, the most common case, and explains how thresholds work, which countries have abolished the tax and how families plan for it.

Inheritance tax by country (2026)
Top rate of inheritance or estate tax on assets left to children, and the tax-free amount. Sort by any column, filter by region, and tap a country for details.
CountryTax-freeTop rate
JapanInheritance tax¥30 million + ¥6 million per heir (whole estate)55%
South KoreaEstate tax₩500 million lump-sum deduction (typical)50%
FranceInheritance tax€100,000 per child45%
United KingdomEstate tax£325,000 + £175,000 for a home left to children40%
United StatesFederal estate tax$15 million per person40%
SpainInheritance tax (regional)From about €16,000; most regions much higher34%
IrelandCapital acquisitions tax€420,000 per child (from 7 October 2026)33%
GermanyInheritance tax€400,000 per child (€500,000 spouse)30%
BelgiumInheritance tax (regional)Low; varies by region27%
South AfricaEstate dutyR3.5 million25%
NetherlandsInheritance taxAbout €26,000 per child20%
DenmarkEstate dutyAbout DKK 340,00015%
BrazilITCMD (state tax)Varies by state8%
ItalyInheritance tax€1 million per child4%
SwitzerlandCantonal taxMost cantons exempt children0%
CanadaNo inheritance taxCapital gains tax at death instead0%
AustraliaNo inheritance tax—0%
New ZealandNo inheritance tax—0%
SwedenNo inheritance tax—0%
NorwayNo inheritance tax—0%
AustriaNo inheritance tax—0%
PortugalStamp dutySpouses, children and parents exempt0%
IndiaNo inheritance tax—0%
ChinaNo inheritance tax—0%
MexicoNo inheritance tax—0%
SingaporeNo inheritance tax—0%
Hong KongNo inheritance tax—0%
United Arab EmiratesNo inheritance tax—0%
28 countries shown; median about 4%
Rules for 2026, checked against national tax authorities and advisers' summaries. Rates are for children; spouses are exempt in most countries, and rates for other relatives and unrelated heirs are often much higher. Thresholds may apply to each heir's share or to the whole estate, as noted. This is a summary, not tax advice.

Inheritance Tax and Estate Tax: What Is the Difference?

Countries tax inheritances in two ways:

Diagram comparing an estate tax on the whole estate with an inheritance tax charged on each heir
The UK and US tax the estate; France, Germany and Japan tax each heir's share, with separate allowances.
  • An estate tax is charged on the whole estate before it is shared out, regardless of who inherits. The UK, the US, South Korea, Denmark and South Africa use estate taxes. The threshold applies to the estate as a whole.
  • An inheritance tax is charged on what each heir receives, usually with rates and allowances that depend on how closely related the heir is to the person who died. France, Germany, Ireland, Spain, Italy, Belgium, the Netherlands and Japan use this approach. Children usually pay far less than distant relatives or unrelated heirs.

The difference matters for families with several children. Under an inheritance tax, each child gets their own allowance: in Germany, three children can each inherit €400,000 tax-free, €1.2 million in total. Under an estate tax, the threshold is shared.

The Highest Inheritance Taxes

  • Japan: up to 55%. The tax-free amount is ¥30 million plus ¥6 million per statutory heir, so about ¥48 million (about $305,000) for a widow with two children. Above that, each heir's share is taxed at rates from 10% to 55%, with the top rate applying above ¥600 million. Generous deductions for spouses mean most of the tax falls on children.
  • South Korea: up to 50%. The top rate applies above ₩3 billion, and large shareholdings in listed companies face an additional valuation premium. The government plans to switch from taxing the whole estate to taxing each heir's share from 2028, which would reduce the tax for many families.
  • France: up to 45% for children. Each child can inherit €100,000 tax-free every 15 years, and rates then rise from 5% to 45%. Spouses are fully exempt, but rates for siblings and unrelated heirs reach 45% and 60%.
  • United Kingdom: 40%. Above the nil-rate band of £325,000 and the residence nil-rate band of £175,000 for a home left to direct descendants. Both pass to a surviving spouse, so a couple can leave up to £1 million tax-free. Both allowances are frozen until at least 2030.
  • United States: 40%. But only on estates above $15 million per person ($30 million for a married couple) from 2026, a level set permanently by the 2025 tax law and indexed to inflation. Fewer than one in 1,000 estates pays federal estate tax. About a dozen states and Washington DC levy their own estate taxes, some from $1 million to $2 million, and a few states charge inheritance tax on heirs.

Countries With Low Inheritance Taxes

  • Italy: spouses and children pay just 4% on amounts above €1 million each.
  • Spain: the national scale reaches 34%, but regional governments set reliefs, and in Madrid, Andalusia and several other regions children and spouses pay almost nothing.
  • Denmark: a flat 15% on amounts above an exemption of about DKK 340,000 for children.
  • Switzerland: almost all cantons exempt spouses and children. In November 2025, voters rejected a proposed 50% federal tax on estates above CHF 50 million.
  • Brazil: state taxes of up to 8%.

Countries With No Inheritance Tax

Many countries have abolished inheritance taxes, arguing that they raise little money, encourage avoidance and penalise family businesses:

Globe with a list of countries that have no inheritance tax, including Canada, Australia, Sweden, India and Singapore
Countries with no inheritance or estate tax. Some, such as Canada, tax capital gains at death.
Bar chart of top inheritance tax rates for children: Japan 55%, South Korea 50%, France 45%, UK and US 40%
Top rate on assets left to children. Thresholds differ hugely: the US taxes only estates above $15 million.
  • Canada has had no inheritance tax since 1972, but treats a person's assets as sold at death, so capital gains tax is due on any gain, except on transfers to a spouse and the family home.
  • Australia abolished state and federal death duties in the late 1970s and early 1980s. Heirs take over the deceased's capital gains tax position.
  • New Zealand (1992), India (1985), Sweden (2005), Austria (2008), Singapore (2008), Hong Kong (2006) and Norway (2014) have all abolished their taxes.
  • China, Mexico, the UAE and most Gulf states have never had a broad inheritance tax.
  • Portugal exempts spouses, children and parents, charging 10% stamp duty only on other heirs.

"No inheritance tax" does not always mean no tax at all. Property transfer taxes, capital gains taxes at death and probate fees can still apply, and assets abroad may be taxed by the country where they are located.

Worked Example: A 1 Million Estate Left to Two Children

To show how much the allowances matter, here is the approximate tax on an estate of 1 million in local currency, split equally between two adult children, with no surviving spouse and no special reliefs:

Approximate inheritance tax on a 1 million estate left to two children in the US, Italy, Germany, Ireland, France and the UK
Approximate tax on 1 million in local currency left to two adult children, no spouse or special reliefs.
CountryEstateApproximate tax
United States$1,000,000$0 (federal), unless a state tax applies
Canada, AustraliaC$/A$1,000,000No inheritance tax (capital gains tax may apply)
Italy€1,000,000€0 (each child below €1 million)
Germany€1,000,000About €22,000 (11% on €100,000 per child)
Ireland€1,000,000About €52,800 (33% on €80,000 per child)
France€1,000,000About €156,000 (about €78,000 per child)
United Kingdom£1,000,000£200,000 if it includes a family home, £270,000 if not

The same estate could therefore cost nothing in one country and more than a quarter of its value in another. A married couple in the UK who leave everything to each other first, and include the family home, can pass on £1 million with no tax at all, which is why planning matters so much there.

Recent Changes

  • United States: the 2025 tax law made a $15 million exemption permanent from January 2026, avoiding a scheduled fall to about $7 million.
  • United Kingdom: from April 2026, 100% relief for farms and family businesses is limited to the first £2.5 million of qualifying assets (raised from a planned £1 million), with 50% relief above; and from April 2027, unused pension funds will be included in estates for inheritance tax for the first time.
  • Ireland: the tax-free threshold for children rose from €400,000 to €420,000 for inheritances from 7 October 2026.
  • South Korea: a reform to tax each heir's share instead of the whole estate is planned for 2028.
  • Switzerland: a federal inheritance tax on very large estates was rejected by voters in November 2025.

How Families Reduce Inheritance Tax Legally

The rules differ by country, but the main legitimate approaches are similar:

  1. Use the spouse exemption wisely. In most countries, leaving everything to a spouse defers the tax, but it can waste the first spouse's allowance where allowances do not transfer. In the UK, unused allowances do pass to the surviving spouse.
  2. Give during your lifetime. Many countries exempt or reduce tax on gifts made several years before death: seven years in the UK, ten years in Germany and 15 years in France, where allowances renew. Small annual gifts are usually tax-free.
  3. Use business and farm reliefs where they apply, which can cut or remove the tax on qualifying family businesses.
  4. Use life insurance and pensions. In some countries, life insurance written in trust, or French assurance-vie contracts, are taxed more lightly than other assets. Rules for pensions are changing in the UK, so check the latest position.
  5. Give to charity. Gifts to registered charities are usually exempt, and in the UK leaving 10% of an estate to charity cuts the rate on the rest from 40% to 36%.
  6. Make a will and review it. Without one, local intestacy rules decide who inherits, which may not be tax-efficient or what you intended. Our guide What Happens to Your Online Accounts, Crypto and Money When You Die? covers digital assets too.

Cross-border families face extra complexity: an estate may be taxed in the country where the person lived, where the heir lives and where the assets are, and tax treaties cover only some combinations. Professional advice is worth paying for in these cases.

Data Notes

The table shows the main inheritance or estate tax rules in 2026 for assets passing from a parent to a child, based on national tax authorities, government announcements and professional summaries listed in the sources. Top rates are the highest rate that applies to children; thresholds are the main tax-free amounts and may apply to each heir or to the whole estate, as noted. Many countries have additional reliefs, regional variations and special rules for homes, businesses, farms and gifts, which this summary does not cover in full.

Frequently Asked Questions

Which country has the highest inheritance tax?

Japan, with a top rate of 55%, followed by South Korea (50%), France (45% for children, 60% for unrelated heirs) and the UK and US (40%).

Which countries have no inheritance tax?

Canada, Australia, New Zealand, Sweden, Norway, Austria, India, China, Mexico, Singapore, Hong Kong, the UAE and most Gulf states, among others. Some of them tax capital gains at death or charge property transfer taxes instead.

How much can you inherit tax-free in the UK?

£325,000, plus £175,000 if a home is left to children or grandchildren, so up to £500,000 per person and £1 million for a married couple. Everything left to a spouse or civil partner is tax-free.

How much can you inherit tax-free in the US?

Federal estate tax applies only to estates above $15 million per person in 2026. Heirs do not pay federal income tax on what they inherit, but some states have their own estate or inheritance taxes.

Do spouses pay inheritance tax?

In almost all countries in our table, assets left to a spouse or civil partner are fully exempt. Unmarried partners usually do not get the same exemption.

Does inheritance tax apply to assets abroad?

Often yes. Countries typically tax the worldwide assets of people who live there, and the local assets of people who do not. Double tax treaties exist between only some countries.

Final Thoughts

Inheritance tax is one of the most variable taxes in the world: a $1 million estate left to two children could pay nothing in Canada, Australia or the US, little in Germany or Italy, and a substantial amount in the UK, France or Japan. The thresholds matter more than the headline rates for most families.

If your estate might be taxable, the most valuable steps are to make a will, use the spouse exemption and lifetime gifts sensibly, and take advice if you have assets or heirs in more than one country. Rules change often, so review your plans every few years.

Sources

Cite this page: Blog Digest, “Inheritance Tax by Country 2026: Thresholds, Rates and Who Pays”, updated 25 October 2026, https://randomthoughtsever.blogspot.com/2026/10/inheritance-tax-by-country-2026.html

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Rules for 2026 from national tax authorities and professional summaries, checked October 2026. This article is for information and isn't tax or legal advice.