Jurisdictions · By country

Inheritance Tax by Country: 37 Family Office Hubs Compared

Updated 20 October 2026 · data checked 18 October 2026 or later · ✓ How we check

Seventeen of the 37 places we track have no inheritance or estate tax: the UAE (DIFC, ADGM and DMCC), Saudi Arabia, Qatar, Bahrain, Singapore, Hong Kong, India, Malaysia, Mauritius, Cyprus, Liechtenstein, Australia, the Cayman Islands, the Bahamas and the British Virgin Islands (for Saudi Arabia, Qatar, Malaysia, Mauritius and the British Virgin Islands this is reported by advisers, not stated by an official source). Malta, Jersey and Guernsey have no inheritance tax either, but charge duty or fees when assets pass: 5% on inherited property in Malta, with reliefs for the family home, a probate stamp duty in Jersey capped at GBP 100,000, and probate fees in Guernsey capped at GBP 250,000 (both as reported by law firms). Canada has no inheritance tax, but taxes the gains on a person's capital property as if it were sold at death, with a rollover for a spouse, and its provinces charge probate fees (about 1.5% above CAD 50,000 in Ontario). Switzerland, Luxembourg, Monaco and Portugal tax inheritances but mostly spare close family: spouses and children are exempt in most Swiss cantons, Luxembourg exempts spouses and children's legal shares, Monaco charges 0% between parents, children and spouses, and Portugal's 10% stamp duty on inheritances and gifts exempts the spouse, descendants and ascendants. Twelve places tax family members too: 40% above GBP 325,000 in the UK; 40% above USD 15 million per person for US citizens and residents in 2026; 7% to 30% in Germany above allowances of EUR 500,000 for a spouse and EUR 400,000 for each child; 5% to 45% in France for children above EUR 100,000 each, with spouses exempt; 4% in Italy above EUR 1 million per heir for a spouse or child (PwC); 7.65% to 34% on Spain's state scale, with regional reliefs of up to 99% for close family in Madrid and Andalusia, as reported by advisers; 1% to 10% in Greece above EUR 150,000 for close family; 33% in Ireland above EUR 420,000 for a child (announced in Budget 2027 and not yet enacted; EUR 400,000 before); 20% to 25% estate duty in South Africa after ZAR 3.5 million, with bequests to a spouse deductible; 1% to 10% in Turkey above about TL 2.9 million per child or spouse; 10% to 55% in Japan after a basic deduction of JPY 30 million plus JPY 6 million per heir; and in Bermuda, which has no inheritance tax as such, a stamp duty on the Bermuda estate of 5.25% to 21% above BMD 100,000, with legacies to a spouse deducted and no deduction for children.

No inheritance or estate tax found

No inheritance tax, but a duty or fee when assets pass

No inheritance tax, but gains taxed at death

A tax or duty exists, close family mostly exempt

Tax applies to family members

What to take from the table

• Residence decides more than where the assets are. The UK taxes the worldwide assets of people resident for 10 of the last 20 tax years; the US taxes citizens and residents above USD 15 million, while non-residents must file from USD 60,000 of US assets; German nationals who move abroad without keeping a German home stay taxable on everything they inherit or give for five years; Greece exempts residents under its non-dom regime on movable property abroad that they inherit or give.
• No inheritance tax can still mean tax at death. Canada treats a person's capital property as sold just before death and taxes the gain on the final return, with a deferral for property left to a spouse or a spouse trust; in Australia capital gains tax can apply at death if an asset passes to a foreign resident or a tax-advantaged entity such as a charity, and super death benefits paid to non-dependants are taxed at up to 15% or 30% plus the Medicare levy.
• No tax does not mean no rules. Saudi Arabia applies Sharia shares and a will above one third needs the heirs' approval; Malaysia applies faraid to Muslims' estates; Mauritius protects children's shares, as reported by Chambers; Guernsey abolished forced heirship from 2 April 2012, as reported by law firms; in the UAE non-Muslims can register or notarise wills with the DIFC or ADGM Courts.
• Other taxes can apply when wealth passes. India taxes gifts above INR 50,000 from non-relatives as income; Saudi Arabia exempts property passing to heirs within their legal shares from its 5% real estate transaction tax; Portugal's family exemption covers its 10% stamp duty but not the 0.8% duty on gifts of real estate.
• Where the assets sit can matter too. Monaco's duty applies only to assets situated in Monaco; Malta's 5% duty applies to property in Malta and Gozo whatever the heirs' residence; Liechtenstein has no inheritance tax but charges 3.5% on some transfers to legal entities or dedicated assets that are not tax-exempt, when the beneficiaries' shares cannot be valued; Bermuda's estate duty applies whatever the deceased's residence, according to Carey Olsen, but securities held in an exempted undertaking are outside the estate; in the British Virgin Islands a non-belonger who inherits land needs a licence and pays stamp duty on the transfer (Carey Olsen).
• Family businesses get relief where the tax bites. Germany exempts 85% of business assets, or 100% on an irrevocable option if no more than 20% of them are administrative assets, with payroll and holding conditions, as long as the favoured assets from the same person within ten years stay within EUR 26 million, and its Constitutional Court heard challenges to the tax on 12 and 13 October 2026; France's Dutreil regime exempts 75% of the value of company shares passed on with holding commitments, the individual one now six years for transfers from 21 February 2026; Italy exempts businesses and company holdings passed to descendants or the spouse if control or the business is kept for five years; Ireland's business relief cuts the taxable value by 90%.
• Regions can decide. Switzerland is cantonal: Schwyz and Obwalden levy no inheritance tax, and a federal 50% tax on estates above CHF 50 million was rejected by 78.3% of voters on 30 November 2025. Spain's autonomous communities can change the state tax substantially, and Canadian provinces set their own probate fees.

"Inheritance tax" in each row is a one-line summary; each guide gives the full rule with numbered sources. Reported means a law firm or another reliable source, not an official one.