Inheritance Tax for Expats: What Happens to Your Estate When You Retire Abroad

Estate planning is one of the most overlooked aspects of retiring abroad. Where you live when you die can dramatically affect how much of your estate actually reaches your heirs. Inheritance taxes, forced heirship laws, and cross-border complications can erode wealth that took a lifetime to build.

We analyzed inheritance and estate tax data for every country in the Retire Abroad Calculator to help retirees understand the landscape before they move. This guide covers which countries charge inheritance tax, which do not, and the critical legal concepts every expat retiree should understand.

Countries With No Inheritance Tax

Good news first: many popular retirement destinations do not levy any inheritance or estate tax at all. If your estate passes to heirs in these countries, the local government takes nothing.

#	Country	Inheritance Tax
1	Albania	None
2	Armenia	None
3	Australia	None
4	Austria	None
5	Cambodia	None
6	Canada	None
7	China	None
8	Costa Rica	None
9	Cyprus	None
10	Czech Republic	None
11	Egypt	None
12	Estonia	None
13	Ethiopia	None
14	Georgia	None
15	Ghana	None
16	Guatemala	None
17	Hong Kong	None
18	India	None
19	Indonesia	None
20	Israel	None
21	Jordan	None
22	Kenya	None
23	Laos	None
24	Latvia	None
25	Malaysia	None
26	Mexico	None
27	Morocco	None
28	Myanmar	None
29	Nepal	None
30	New Zealand	None
31	Nigeria	None
32	Norway	None
33	Oman	None
34	Panama	None
35	Peru	None
36	Portugal	None
37	Qatar	None
38	Romania	None
39	Saudi Arabia	None
40	Singapore	None
41	Slovakia	None
42	Sri Lanka	None
43	Sweden	None
44	Switzerland	None
45	Tanzania	None
46	UAE	None
47	Uganda	None
48	Uruguay	None

For retirees with significant assets, choosing a country with no inheritance tax can save heirs tens or even hundreds of thousands of dollars. However, remember that as a U.S. citizen, the U.S. federal estate tax still applies to your worldwide estate regardless of where you live.

Countries That Do Charge Inheritance Tax

The following countries impose some form of inheritance or estate tax. Rates, thresholds, and structures vary significantly.

Country	Rate	Threshold	Notes
Bolivia	1%	From first dollar	1% transaction tax on property transfers
Serbia	2.5%	From first dollar	1.5-2.5% for 2nd/3rd order; 1st order exempt
Dominican Republic	3%	From first dollar	3% flat tax on net estate
Montenegro	3%	From first dollar	3% for 2nd order; 1st order exempt
Croatia	4%	From first dollar	4% on property; direct heirs exempt
Luxembourg	5%	From first dollar	0% for spouses; 2-5% for children
Bosnia and Herzegovina	5%	From first dollar	Direct heirs generally exempt; 5% for others
Philippines	6%	PHP 5,000,000	6% flat above 5M PHP standard deduction
Argentina	6.5%	From first dollar	Buenos Aires province only; 2.2-6.5% progressive
Bulgaria	6.6%	From first dollar	0.4-6.6%; direct heirs exempt
Poland	7%	PLN 36,120	3-7% for close family; full exemption if reported in 6mo
Brazil	8%	From first dollar	ITCMD state tax 2-8%; varies by state
Italy	8%	EUR 1,000,000	4% above 1M for children/spouse; 6-8% others
Colombia	10%	From first dollar	10% flat on inherited amounts
Greece	10%	EUR 150,000	1-10% for children/spouse; 150k exemption
Turkey	10%	TRY 1,371,632	1-10% progressive; exemption indexed
Lithuania	10%	EUR 150,000	5% up to 150k, 10% above; family can be exempt
Thailand	10%	THB 100,000,000	5% for 100M-300M; 10% above 300M
Vietnam	10%	VND 10,000,000	10% income tax on inherited assets above 10M VND
Senegal	10%	From first dollar	1-10% for direct heirs
Lebanon	12%	From first dollar	3-12% for direct heirs; varies by kinship
Slovenia	14%	From first dollar	5-14% for 2nd class; children/spouse exempt
Denmark	15%	DKK 321,700	15% for close family; 25% additional for others
Hungary	18%	From first dollar	18% general; direct heirs fully exempt
Finland	19%	EUR 20,000	7-19% progressive; 20k exemption
Netherlands	20%	EUR 25,187	10-20% for children; threshold indexed
Taiwan	20%	TWD 13,330,000	10-20% progressive; 13.33M TWD exemption
Chile	25%	From first dollar	1-25% progressive; direct heirs get deductions
South Africa	25%	ZAR 3,500,000	20% on first 30M above 3.5M; 25% above 30M
Tunisia	25%	From first dollar	2.5% for direct heirs; up to 25% for unrelated
Germany	30%	EUR 400,000	400k exemption per child; 7-30% progressive
Belgium	30%	From first dollar	3-30% for direct heirs; varies by region
Ireland	33%	EUR 335,000	Capital Acquisitions Tax; Group A threshold
Spain	34%	From first dollar	Varies by region; many offer 95-99% reduction
Ecuador	35%	USD 71,870	0-35% progressive above ~$72k
United States	40%	USD 13,610,000	Federal estate tax above $13.61M exemption
United Kingdom	40%	GBP 325,000	IHT above nil-rate band; +175k for family home
France	45%	EUR 100,000	100k allowance per child; 5-45% progressive
South Korea	50%	KRW 500,000,000	10-50% progressive; 500M KRW exemption
Japan	55%	JPY 30,000,000	10-55% progressive; 30M JPY + 6M per heir exemption

How Inheritance Tax Works for Expats

The interaction between U.S. estate tax and foreign inheritance tax creates a complex web that requires professional guidance. Here are the key concepts:

Domicile vs. Residency

Most countries determine inheritance tax liability based on either the domicile (permanent home) of the deceased or the location of assets. Simply living abroad does not always change your domicile for estate tax purposes. The U.S. uses domicile as the primary test for estate tax, while many other countries use residency or asset location.

Double Taxation Risk

If you are a U.S. citizen living in a country that also charges inheritance tax, your estate could theoretically be taxed twice. The U.S. federal estate tax exemption is approximately $13.6 million per person in 2026, so most estates will not owe U.S. estate tax. However, many foreign countries have much lower thresholds. Tax treaties between the U.S. and certain countries may provide relief, but not all countries have estate tax treaties with the United States.

Forced Heirship Laws

Several countries, particularly in continental Europe and Latin America, have forced heirship rules that override your will. These laws reserve a portion of your estate for specific heirs (usually children and spouses), regardless of what your will states. Countries with forced heirship include France, Spain, Italy, Germany, Japan, and most Latin American nations. This is a critical consideration when choosing where to retire.

Foreign Property Complications

If you own real estate abroad, it may be subject to the inheritance laws of the country where the property is located, not where you are domiciled. This means you may need a separate will for foreign assets, drafted under local law and in the local language.

Practical Steps for Expat Estate Planning

• Create separate wills. Have a U.S. will for American assets and a local will for assets in your country of residence. Ensure they do not conflict.
• Understand forced heirship. If your destination has forced heirship laws, consult a local attorney about how they interact with your estate plan.
• Review tax treaties. Check whether the U.S. has an estate or gift tax treaty with your destination country. Treaties can prevent double taxation.
• Consider asset structure. Trusts, holding companies, and other structures may help optimize your estate plan across borders. Professional advice is essential.
• Update beneficiaries. Ensure all U.S. financial accounts, insurance policies, and retirement accounts have up-to-date beneficiary designations.
• Use multi-currency accounts. Services like Wise make it easier to manage assets across currencies and can simplify estate administration.

The Bottom Line

Inheritance tax is a factor that can significantly influence where you choose to retire abroad. Countries with no inheritance tax offer a clear advantage for preserving wealth across generations, but even in countries with inheritance tax, proper planning can minimize the impact. The critical step is to address estate planning before you move, not after.

Use the Retire Abroad Calculator to compare retirement destinations across all dimensions, including tax implications. And remember that this guide is for informational purposes; always consult qualified legal and tax professionals for your specific situation.