Inheritance tax rates is very important to consider when you make a property investment in a foreign country. It should not be ignored and must be a part in any future citizenship and residence planning. This is because when you pass away, the property must passed down to family beneficiaries without taxes.
First you should know inheritance tax, Inheritance tax should not be confused with ‘estate’ tax. Both estate and inheritance taxes are triggered upon death. The basic difference is Estate tax upon death on the entire property, while Inheritance tax applies only the on the inheritance received as a part of your share.
Careful many countries impose heavy inheritance taxes. This is where zero tax countries come into play. When you invest in a real estate property for golden visa, it is absolutely essential you check for inheritance tax rates. In many countries, it is paid by both residents and non-residents.
The countries that offer golden visa programs has the following inheritance rates.
| Inheritance Tax | |
| Portugal | 0% |
| Greece | 1% to 10% – Tax free upto €150,000 |
| Malta | 0% |
| Spain | Inheritance up to €7,993: 7.65% €7,993 – €31,956: 7.65 to 10.2% €31,956 – €79,881: 10.2 to 15.3% €79,881 – €239,389: 15.3 to 21.25% €239,389 – €398,778: 25.5% €398,778 – €797,555: 29.75% €797,555+: 34% |
| United Kingdom | 40% standard rate |
| United States | 40% |
| Canada | 0% |
| Australia | 0% |
| New Zealand | 0% |
| Ireland | 33% |
| Bulgaria | 0.4 % to 0.8 % upto BGN 250,000 3,3% and 6,6 % above BGN 250,000 |
| Cyprus | 0% |
| Turkey | upto 30% |
| Montenegro | 3% |
You can see from the above why Portugal, Malta, Canada, Australia are so attractive for real estate investments for the future of your family because these countries levy zero inheritance tax.
The Caribbean countries may also be attractive for real estate investment for citizenship by investment, as there is no capital gains tax, no income tax, no inheritance / estate taxes.
High Inheritance Tax
| Country | Top Rate to Lineal Heir | Tax Type |
| Japan | 55% | Inheritance Tax |
| South Korea | 50% | Inheritance Tax |
| France | 45% | Inheritance Tax |
| United Kingdom | 40% | Inheritance Tax |
| United States | 40% | Estate Tax |
| Ecuador | 35% | Inheritance Tax |
| Spain | 34% | Estate Tax |
| Ireland | 33% | Capital Acquisitions Tax |
| Belgium | 30% | Inheritance Tax |
| Germany | 30% | Inheritance Tax |
| Chile | 25% | Estate Tax |
| Venezuela | 25% | Inheritance Tax |
| Bermuda | 20% | Estate Tax via Stamp Duty |
| Greece | 20% | Inheritance Tax |
| Netherlands | 20% | Inheritance Tax |
| Philippines | 20% | Estate Tax |
| South Africa | 20% | Estate Duty |
| Finland | 19% | Inheritance Tax |
| Angola | 15% | Inheritance Tax |
| Denmark | 15% | Inheritance Tax |
| Lebanon | 12% | Inheritance Tax |
| Malawi | 11% | Estate Duty |
| Cameroon | 10% | Estate Tax |
| Equatorial Guinea | 10% | Inheritance Tax |
| Iceland | 10% | Inheritance Tax |
| Puerto Rico | 10% | Estate Tax |
| Taiwan | 10% | Estate Tax |
| Turkey | 10% | Inheritance Tax |
Low Inheritance Tax
| Brazil | 8% | Estate Tax |
| Poland | 7% | Inheritance Tax |
| Switzerland | 7% | Inheritance Tax (cantonal) |
| Aruba | 6% | Inheritance Tax |
| Curacao | 6% | Inheritance Tax |
| Guatemala | 6% | Inheritance Tax |
| Sint Maarten | 6% | Inheritance Tax |
| Botswana | 5% | Capital Transfer Tax |
| Croatia | 5% | Estate Tax |
| Zimbabwe | 5% | Estate Tax |
| Italy | 4% | Inheritance Tax |
| Guinea | 3% | Inheritance Tax |
| Senegal | 3% | Inheritance Tax |
| Mozambique | 2% | Inheritance Tax |
| Jamaica | 2% | Transfer Tax (rates specific to death) |
| Bulgaria | 1% | Inheritance Tax |
Zero Inheritance Tax
| Lithuania | 0% | Inheritance Tax |
| Luxembourg | 0% | Inheritance Tax |
| Macedonia | 0% | Inheritance Tax |
| Morocco | 0% | Estate Tax |
| Serbia | 0% | Inheritance Tax |
| Slovenia | 0% | Inheritance Tax |
| Tunisia | 0% | Inheritance Tax |
| Hungary | 0% | Inheritance Tax |
| Australia | 0% | – |
| Austria | 0% | – |
| Canada | 0% | – |
| China | 0% | – |
| Estonia | 0% | – |
| Hong Kong | 0% | – |
| Israel | 0% | – |
| Macau | 0% | – |
| Mexico | 0% | – |
| New Zealand | 0% | – |
| Norway | 0% | – |
| Portugal | 0% | – |
| Serbia | 0% | – |
| Russia | 0% | – |
| Slovak Republic | 0% | – |
| Slovenia | 0% | – |
| Sweden | 0% | – |
Sources: Tax Foundation
Europe
In Europe, only few states have zero inheritance tax according to European commission report. You can compare here inheritance, gift, wealth and estate taxes in EU member states in one place.
Source: European Commission
