In short
Of the twelve countries on this page, the United States, the United Kingdom, Japan, South Korea and France tax an estate or an inheritance that reaches a non-resident, each on its own test, and Switzerland does so at cantonal level on real estate situated there.
| Country | Inheritance tax | Scope for a non-resident | Rate or threshold | Legal basis | Law read on | Page |
|---|---|---|---|---|---|---|
| Australia | Inheritance taxNo | Scope for a non-residentNo inheritance or estate tax, whatever the residence of the deceased or the heir. A super death benefit paid to a non-dependant is taxed, and the gain on an asset left to a foreign resident is taxed in the deceased's final return unless it is taxable Australian property. | Rate or thresholdSuper: up to 15% on the taxed element and 30% on the untaxed element, without the Medicare levy for a foreign resident. | Legal basisATO; ITAA 1997 ss. 302-145, 104-215 | Law read on12 October 2026 | Calculator |
| China | Inheritance taxNo | Scope for a non-residentNo inheritance or gift tax has been legislated. On a home, a statutory heir pays neither deed tax nor income tax; a gift bears deed tax, and income tax unless it goes to close family. | Rate or thresholdDeed tax 3% to 5%, set by the province; income tax 20% on a gift outside close family. | Legal basis契税法 art. 6(5); 财税〔2009〕78号 art. 1; 2019 announcement No. 74 | Law read on27 September 2026 | Calculator |
| France | Inheritance taxYes | Scope for a non-residentThe worldwide estate is taxed when the heir has been domiciled in France for at least six of the previous ten years, even if the deceased lived abroad. | Rate or thresholdDirect line 5% to 45% after an allowance of 100 000 euros per child and per parent; 60% between unrelated people. | Legal basisCGI arts. 750 ter 3, 777, 779 I | Law read on23 September 2026 | Calculator |
| India | Inheritance taxNo | Scope for a non-residentNo inheritance or estate tax; estate duty was abolished in 1985, and property inherited is exempt from income tax. Gifts from non-relatives above 50 000 rupees in a year are taxed as income on their whole amount. | Rate or thresholdIncome tax at the recipient's rate; under the new regime the rate reaches 30% above 24 lakh rupees. | Legal basisIncome-tax Act, 2025, ss. 92(2)(m), 156, 202(1) | Law read on27 September 2026 | Calculator |
| Japan | Inheritance taxYes | Scope for a non-residentAn heir living abroad is taxed on assets in Japan only, unless a worldwide rule applies; those rules turn on the nationality and the addresses of the deceased and the heir in the ten years before death. | Rate or threshold10% to 55% on each heir's notional legal share, after a basic deduction of 30 000 000 yen plus 6 000 000 yen per legal heir. | Legal basis相続税法 arts. 1-3, 15, 16; NTA No.4138 | Law read on12 October 2026 | Calculator |
| Russia | Inheritance taxNo | Scope for a non-residentThe inheritance and gift tax was abolished from 1 January 2006, and inheritance is exempt from income tax. Real estate, vehicles, shares, digital financial assets or stakes received as a gift from anyone outside close family are taxable income. | Rate or threshold30% for a non-resident on such a gift. Notarial duty 0.3%, at most 100 000 roubles, for close heirs; 0.6%, at most 1 000 000 roubles, for others. | Legal basisНК РФ ст. 217(18), 217(18.1), 224(3), 333.24 | Law read on27 September 2026 | Calculator |
| Singapore | Inheritance taxNo | Scope for a non-residentNo inheritance or estate tax on a death on or after 15 February 2008. A home passed by assent under the will or the law bears no stamp duty. | Rate or thresholdA home given during lifetime bears Buyer's Stamp Duty up to 6%, plus Additional Buyer's Stamp Duty for a foreign recipient or a second or later home. | Legal basisIRAS | Law read on27 September 2026 | Calculator |
| South Korea | Inheritance taxYes | Scope for a non-residentA non-resident deceased is taxed on assets in Korea only, and keeps only the basic deduction of 200 000 000 won. | Rate or threshold10% to 50%; a credit of 3% of the tax for a return filed on time. | Legal basis상속세 및 증여세법 arts. 3, 18, 26, 69 | Law read on27 September 2026 | Calculator |
| Switzerland | Inheritance taxCantonal | Scope for a non-residentNo federal tax. Real estate is taxed in the canton where it is situated, movable assets at the last domicile of the deceased; the canton where the beneficiary lives is never relevant. | Rate or thresholdSet by each canton. Obwalden and Schwyz levy no inheritance tax; the surviving spouse is exempt in all 24 cantons that tax, direct descendants in 21. | Legal basisCantonal laws; Federal Tax Administration compilation | Law read on1 January 2025 (FTA compilation) | Calculator |
| United Arab Emirates | Inheritance taxNo | Scope for a non-residentNo inheritance, estate or gift tax. Succession follows the law of the deceased's nationality, and a non-Muslim may leave all property in the UAE by will to anyone. | Rate or thresholdNone. | Legal basisFederal Decree-Law 25 of 2025, art. 17(1); Federal Decree-Law 41 of 2022, art. 11 | Law read on23 September 2026 | Guide |
| United Kingdom | Inheritance taxYes | Scope for a non-residentA person who is not a long-term UK resident, meaning UK resident in fewer than 10 of the previous 20 tax years, is taxed on UK assets only. | Rate or threshold40% above the nil-rate band of 325 000 pounds. | Legal basisIHTA 1984 ss. 6(1), 6A, Schedule 1 | Law read on12 October 2026 | Calculator |
| United States | Inheritance taxYes | Scope for a non-residentA deceased who is neither a US citizen nor domiciled in the United States is taxed on assets situated in the United States only, such as US real estate and shares of US companies. | Rate or threshold18% to 40%; a return is required above 60 000 dollars of US-situated assets. | Legal basisIRC 2001(c), 2102(b)(1), 2103 | Law read on12 October 2026 | Calculator |
The rows are in alphabetical order. There is no ranking: which country suits a family depends on where its members live and where its assets are, not on the rates alone.
Frequently asked questions
› Which countries tax a non-resident on an inheritance?
Of the twelve countries on this page, the United States, the United Kingdom, Japan, South Korea and France tax an estate or an inheritance that reaches a non-resident, each on its own test, and Switzerland does so at cantonal level on real estate situated there.
› Which countries have no inheritance tax?
Australia, China, India, Russia, Singapore and the United Arab Emirates levy no inheritance tax. Some transfers still bear tax there: a super death benefit in Australia, deed tax on a gift of a home in China, income tax on gifts from non-relatives in India and Russia, and stamp duty on a gift of a home in Singapore.
› Does the heir's residence matter?
In France and Japan it does: France taxes the worldwide estate of an heir domiciled there for six of the previous ten years, and Japan looks at the nationality and addresses of both the deceased and the heir. In the United Kingdom and the United States the test turns on the deceased. In Switzerland the canton where the beneficiary lives is never relevant.
General information, compiled from the country pages and their official sources. It does not take account of any particular situation.
Structuring the estate
Other jurisdictions
Switzerland
Gift and inheritance tax
France
Gift and inheritance tax
United Arab Emirates
Succession, wills and guardianship
United States
Estate tax on a nonresident's US assets
United Kingdom
Inheritance tax, residence based regime
Japan
Inheritance tax, residents and non-residents
South Korea
Inheritance tax, resident or non-resident deceased
Australia
Super and capital gains at death
Russia
Notary duty and tax on gifts
China
Deed tax and income tax on a home
Singapore
Stamp duty and succession
India
Tax on gifts from non-relatives