What should you know about Inheritance Tax

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.

Inheritance Tax in Europe

Source: European Commission

 

Prabhu Balakrishnan

Prabhu Balakrishnan

Founder and CEO of Best Citizenships

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