Dying Somewhere Else: Where to Move for a Good Estate Plan, and Why Moving Is Almost Never Enough
Some 20 developed countries no longer tax inheritances, and others openly court large fortunes with custom-built regimes. But the tax on passing wealth along is the stickiest of all — a world tour of the destinations, and an inventory of the rules that actually decide the bill.
Some 20 developed countries no longer tax inheritances, and others openly court large fortunes with custom-built regimes. But the tax on passing wealth along is the stickiest of all: it follows sometimes the deceased, sometimes the heir, sometimes the asset, occasionally the passport, and often for ten years after you leave. A world tour of the destinations, and an inventory of the rules that actually decide the bill.
A Tax in Retreat, Except Where It Counts
The OECD laid it out in its 2021 study: 24 of its 38 members still tax inheritances, estates, or gifts, and the tax brings in on average only half a percent of total tax revenue. A dozen or so countries have abolished it since the 1970s: Canada and Australia first, then New Zealand, Sweden in 2004, Austria and Norway more recently.
Where it survives, it can be heavy. Japan tops out at 55%, South Korea at 50%, France at 45% for children and 60% between unrelated people, the United Kingdom and the United States at 40%, Spain at 34% before multipliers that can push the rate well beyond that, Germany at 30% for children and 50% for unrelated heirs. Belgium reaches 80% between non-relatives in Wallonia and Brussels. Those headline rates say little without the exemptions: $15 million per person in the United States starting in 2026, €400,000 per child in Germany, €100,000 in France, €1 million in Italy.
This is what the expat guides leave out: the question isn't whether a country taxes estates, but whether it will tax yours.
Who Taxes What: The Four Tests
The whole subject turns on the connecting factor, and countries use four of them, often in combination.
The deceased or the donor. This is the most common test: the country where the deceased was resident, or domiciled in the common-law sense, taxes the entire worldwide estate. Leaving makes it go away, eventually.
The heir. Germany, Spain, France, and Japan also tax based on who receives. A parent living in Dubai who leaves a Swiss portfolio to a daughter living in Munich or Madrid has saved nothing: she will pay German or Spanish tax on what she receives. France applies the same rule when the heir has lived there at least six of the past ten years. Moving abroad alone, leaving your children behind, therefore does nothing in those countries. It is the leading reason relocation plans fail.
The asset. Real estate is taxed where it sits, no matter where anyone lives. Many countries add certain local assets. The United States goes further: a nonresident alien who dies holding U.S.-situs property, stock in U.S. companies included, is taxable above just $60,000, against $15 million for an American. A European with a brokerage account full of U.S. stocks has a U.S. estate tax problem without knowing it, one that only 16 treaties soften.
Citizenship. The United States taxes the estates of its citizens wherever they live. Germany keeps hold of its nationals for five years after they leave, ten if they move to the United States, under the bilateral treaty. The Netherlands does the same for ten years for inheritances, and for one year for gifts regardless of nationality.
The Long Tails
Even when the test is residence, leaving doesn't wipe the slate clean right away. In April 2025, the United Kingdom replaced its old domicile test with a long-term residence rule: anyone who has been U.K. resident for ten of the past twenty years remains taxable on worldwide assets for three to ten years after leaving, depending on how long they stayed. Japan follows its nationals for ten years. Ireland has a five-year rule.
For Americans, the only exit is renouncing citizenship, with an immediate mark-to-market tax on unrealized gains for those with a net worth above $2 million, and a lesser-known provision: gifts and bequests the former citizen later makes to U.S. persons are taxed at 40% in the recipient's hands, with no meaningful exemption. If your children remain American, you have merely moved the tax.
And estate tax isn't the only tax. Several countries without one tax capital gains at death: Canada treats the deceased as having sold everything at fair market value on the day of death, and Australia carries the gain over to the heir. By contrast, the United States and the United Kingdom give assets a step-up in basis at death, wiping out the built-in gain. A country with no inheritance tax but a capital gains tax at death can cost more than a country that taxes estates with a high exemption.
The Europe That Doesn't Tax, or Barely
Switzerland has no federal inheritance tax, and voters rejected a 2015 initiative that would have created one at 20%. The matter is cantonal: nearly every canton exempts the spouse and descendants, Schwyz and Obwalden tax no one, while Vaud, Neuchâtel, and Appenzell Innerrhoden tax children moderately. Rates between unrelated people, however, can exceed 40% in Geneva or Basel. Combined with lump-sum taxation, available to foreigners with no gainful activity in the country, Switzerland remains the benchmark destination for European wealth. One caution: France terminated its estate tax treaty with Bern, which lapsed at the start of 2015, so heirs living in France and French assets are fully taxed in France.
Italy has one of the gentlest regimes in Western Europe: 4% for direct descendants above €1 million per heir, 6% between siblings and other relatives, 8% for unrelated heirs. Passing a business to descendants is exempt if control is kept for five years, and real estate is valued on a cadastral basis far below market. New residents who elect the flat tax on their foreign income also have their non-Italian assets exempted from inheritance and gift tax for as long as the election lasts. For mobile wealth, it is the most complete package on the continent.
Portugal abolished its inheritance tax in 2004. Spouse, descendants, and ascendants are exempt; other beneficiaries pay a 10% stamp duty, only on assets located in Portugal. Austria let its tax expire in 2008 and now collects only a transfer tax on real estate, along with a gift reporting requirement. Sweden and Norway have nothing left, though Norway has an annual wealth tax and an exit tax that have driven several of its large fortunes to Switzerland. Cyprus, Malta, Estonia, Latvia, Slovakia, and Romania don't tax inheritances, Malta settling for a duty on real estate transfers.
Others exempt close family without abolishing the tax: Luxembourg for direct descendants of its residents, Poland subject to a filing within six months, Hungary, the Czech Republic, Slovenia, Croatia, Bulgaria, and for the most part Greece, which has raised the exemption on gifts between parents and children to €800,000. Monaco doesn't tax direct descendants or the spouse, and taxes only assets located in the principality; French nationals there remain subject to French income tax under the 1963 treaty, and their heirs living in France remain taxable.
Spain deserves a paragraph of its own. The tax is national, but the regions set the reductions. Madrid, Andalusia, Murcia, the Canary Islands, the Balearics, and Valencia exempt transfers between close relatives at 99% or close to it, while Asturias and Catalonia tax considerably more. Since a 2014 ruling by the EU's Court of Justice, later extended by Spanish case law to non-EU countries, nonresidents can invoke the regional rules. The deceased's region of residence is determined over the last five years, which rules out the last-minute move.
Outside Europe
The United Arab Emirates has no inheritance tax, no gift tax, and no personal income tax. The risk there is civil, not fiscal: without a will, courts may apply sharia, which imposes fixed and unequal shares. A 2023 federal law lets non-Muslims opt out of that regime, and wills registered with the DIFC or Abu Dhabi courts lock in the distribution. Going without one is the classic mistake of the Gulf expat.
Singapore abolished its estate duty in 2008, Hong Kong in 2006. Israel has had none since 1981 and exempts new immigrants' foreign income for ten years, though reporting on that income became mandatory for new arrivals from 2026 on.
Australia and New Zealand have had none for decades, with the caveat already noted about Australian capital gains. Canada taxes the gain at death and charges probate fees of about 1.5% in Ontario and 1.4% in British Columbia. Mexico, Panama, Costa Rica, and Uruguay don't tax inheritances in practice, or do so at token rates.
In the United States, the federal estate tax has touched only a tiny minority of estates since the exemption was raised, now made permanent at $15 million by the July 2025 law. But a dozen states and the District of Columbia levy their own estate tax with much lower thresholds: $1 million in Oregon, $2 million in Massachusetts, about $3 million in Washington State, whose top rate briefly rose to 35% in 2025 before lawmakers rolled it back to 20% in July 2026. Five states also tax heirs through an inheritance tax, with Maryland imposing both. For an American, settling in Florida, Texas, or Nevada is the most effective and cheapest form of estate-driven relocation.
Giving While You're Alive
The lifetime gift is often the most powerful tool, provided you're in the right place at the right time.
The United Kingdom doesn't tax gifts between individuals if the donor survives seven years, with taper relief starting in the third year. Germany's exemptions reset every ten years, France's every fifteen. Italy applies its 4% to 8% rates to gifts with the same thresholds. Belgium offers a peculiarity: a registered gift of movable property to a child pays 3% in Flanders and Brussels and 3.3% in Wallonia, against inheritance tax rates that climb to 27% or 30%. Unregistered, it escapes tax entirely if the donor survives five years in Wallonia and Brussels, three in Flanders. Switzerland, depending on the canton, Austria, Portugal, and Sweden don't tax gifts to children.
Americans have the annual exclusion, roughly $19,000 per recipient, and the unified $15 million exemption. Two wrinkles matter for binational couples: gifts to a noncitizen spouse don't qualify for the unlimited marital deduction but for an annual cap of about $194,000, and a bequest to a noncitizen spouse is deferred only through a qualified domestic trust (QDOT). Conversely, a nonresident alien owes U.S. gift tax only on real estate and tangible property located in the United States, not on stock, which opens a transfer route that the estate tax does not.
The trap in gifting after a move is twofold: the child who stayed in a country that taxes the recipient, and anti-abuse rules when the move had no other purpose. For Americans there is an additional trade-off: a gifted asset keeps its original carryover basis, while an inherited asset gets a step-up. Giving away a highly appreciated asset can cost more in capital gains tax than it saves in estate tax.
Civil Law, the Other Half of the Problem
Choosing a country also means choosing who inherits. Civil-law countries protect descendants through forced heirship: in France, three-quarters of the estate must go to the children if there are three or more. Germany gives them a cash claim equal to half their statutory share. English law and the law of most U.S. states allow almost complete freedom, subject to the spouse's rights.
In the European Union, except Denmark and Ireland, a regulation in force since August 2015 applies the law of the deceased's last habitual residence to the entire estate. A Briton or an American living in Spain therefore has, by default, an estate governed by Spanish law and its forced shares. The same regulation provides the fix: anyone can choose the law of their nationality in a will. An American designates the law of the state with which he has the closest connection. That choice is purely civil and changes nothing about the tax.
France has been an exception since a 2021 law: when the foreign law has no forced heirship, children can claim a compensatory share out of assets located in France, provided the deceased or one of the children is a national or resident of an EU country. The European Commission opened an infringement procedure over the law's compatibility with the regulation, which it moved to close in 2026 after accepting France's justification.
Add matrimonial property regimes, which determine what falls into the estate in the first place: a couple that moves can change regimes without knowing it.
Trusts, Foundations, and Wrappers
The expat who leaves a common-law country for continental Europe often brings a trust along, and that's a nasty surprise. Since 2011, France has imposed heavy reporting obligations on trusts with a French settlor, beneficiary, or asset, taxes transfers through them at up to 60%, and penalizes each failure to report at €20,000, or a steeper share of the trust's assets if that works out higher. Germany taxes the funding of a family foundation as a gift, then hits it every thirty years with a substitute tax simulating an inheritance. Italy clarified in 2024 that the tax is due on distribution to beneficiaries, with an election to pay on the way in. Belgium applies a look-through tax to foreign structures.
Conversely, some local instruments are remarkably effective: French life insurance, which passes €152,500 per beneficiary outside the estate for premiums paid before age 70, the Luxembourg policy for its portability from country to country, and foundations in Liechtenstein or the Emirati financial centers for continuity of control. The classic mistake of the American retiree in France or Spain is to keep a revocable living trust, a routine tool back home and a source of tax and reporting headaches in the host country.
Double Taxation, for Want of Treaties
Income tax treaties number in the thousands. Those covering estates and inheritances total fewer than a hundred worldwide. The United States has 16, including with France, Germany, the United Kingdom, the Netherlands, Italy, Switzerland, and Japan, plus a protocol with Canada. The United Kingdom has about ten, France about ten, Germany six.
Without one, two countries can tax the same asset, one through the deceased, the other through the heir or the asset's location, and unilateral tax credits don't always apply. A resident of Spain who inherits from a parent who died in Germany, or an American who dies in Portugal with heirs in Germany, can face two partly overlapping taxes. Checking whether a treaty exists among the country you're leaving, the country you're moving to, and the country where your heirs live is the first piece of due diligence, and the most neglected.
The Windows Are Closing
These regimes move, almost always in the same direction. The United Kingdom abolished non-dom status in 2025 and decided to bring unused pension funds into inheritance tax starting in April 2027. Italy raised its flat tax from €100,000 to €200,000 in 2024, then to €300,000 in 2026. Germany is debating the privilege granted to family businesses, which its Constitutional Court already struck down once in 2014. Norway tightened its exit tax. In Switzerland, the Young Socialists' initiative proposing a 50% federal tax above 50 million francs went to a vote on November 30, 2025, and was rejected by 78.3% of voters; its mere announcement had nonetheless led several families to postpone their move beforehand. In the United States, the 2025 permanence can be undone by a different majority.
An estate plan plays out over twenty or thirty years. The regime in force the day you move is unlikely to be the one in force the day you die.
So, Where?
There's no single answer, only configurations.
For a European whose children are willing to leave too, or already live in a country that doesn't tax the heir: Switzerland, Italy under the flat tax, Portugal, or the Emirates, depending on the life you want. For one whose children are staying in Germany, Spain, or France, the parents' departure solves nothing, and early gifting within the national exemptions remains the main tool. For a Briton, the calendar is the key variable: up to ten years of nonresidence to get out of scope, seven years of survival to clear a gift. For an American, no country changes the federal tax, which in any case concerns only estates above $15 million per person; the real issues are the state of residence, and then avoiding a foreign tax on top of the U.S. one, which points to countries with no inheritance tax or with a treaty. For everyone, real estate kept in the home country will remain taxable there.
Practitioners add a non-tax rule: don't spend the end of your life in a country where you don't want to live. Moves driven solely by estate planning often come undone with a return home for health or family reasons, which reestablishes the original residence at the worst possible moment.
Before You Go
Map the three geographies: where the assets are, where the heirs are, and what passports are involved. Check the applicable treaties. Draw up a will that designates the governing law, coordinated across the countries involved, rather than several wills that revoke one another. Make the move real, provable, and lasting. Give early. Revisit the plan every five years.
Inheritance tax is the tax that has retreated furthest around the world and the one people flee least successfully. You can escape a tax authority by changing countries. You can't escape a family, and it is the family, by where it lives, that most often determines the bill.
A note on method: this article is general information, not tax, legal, or estate-planning advice, and each cross-border situation needs its own lawyer or notary in every country involved. The rates, exemptions, and rules cited above — including the U.S. federal and state estate tax thresholds, Italy's flat-tax amount, Belgium's regional gift rules, the U.K.'s long-term residence rules, the heir-based rules in France, Germany, Spain, and Japan, the number of estate tax treaties held by each country, the status of the EU proceedings over the 2021 French law, and the result of the November 2025 Swiss vote — were checked against official and professional sources current as of September 2026. These rules move quickly and should be reconfirmed with a qualified professional in each country involved before you rely on them.