The Netherlands operates a beneficiary-based inheritance tax system, unlike the UK, where inheritance tax (IHT) is generally charged on the deceased’s estate. In the Netherlands, each beneficiary is taxed individually according to the value they inherit and their relationship to the deceased, with different exemptions and tax rates applying to spouses, children and other recipients.
The Netherlands also imposes gift tax on certain lifetime transfers, with exemptions that can form part of a longer-term estate planning strategy.
For UK expatriates living in the Netherlands or planning to relocate, these differences are important when considering how assets will pass to family members. Dutch inheritance and gift tax may need to be considered alongside UK IHT, particularly where UK long-term residence rules continue to apply after departure.
What You Will Learn
- How Dutch inheritance tax rates and exemptions differ according to the beneficiary
- How annual gift tax exemptions can support lifetime wealth transfers
- When Dutch inheritance tax and UK IHT may both apply to your estate
- What to consider when planning an estate with UK and Dutch assets
What Is the Inheritance Tax in the Netherlands?
In the Netherlands, inheritance tax is charged progressively on individual beneficiaries based on the value they inherit. The tax payable depends on the amount inherited after exemptions and the beneficiary’s relationship to the deceased.
The Netherlands also charges gift tax on certain lifetime transfers where the value exceeds the applicable exemptions. Both taxes follow similar relationship-based principles, although gift tax also provides annual exemptions that can support lifetime wealth transfers.
In the UK, inheritance tax is generally charged on the deceased’s estate before assets pass to beneficiaries. UK inheritance tax is therefore generally an estate-based tax, although certain lifetime transfers and other arrangements can also give rise to IHT liabilities.
For UK expatriates, both systems may apply to the same estate. Understanding both systems can help identify where tax liabilities may overlap and where cross-border inheritance tax planning may be needed.
How Much Is Inheritance Tax in the Netherlands?
Dutch inheritance tax rates range from 10% to 40%, with the specific rate depending on the value of the inheritance and the relationship between the deceased and the beneficiary. The rates apply to the amount above the beneficiary’s tax-free exemption.
| Relationship to the Deceased | Exemption | Tax Rate (on excess up to €158,669) | Tax Rate (on excess over €158,669) |
|---|---|---|---|
| Spouse/qualifying partner | €828,035 | 10% | 20% |
| Children/stepchildren/foster children | €26,230 | 10% | 20% |
| Grandchildren | €26,230 | 18% | 36% |
| Great-grandchildren | €2,769 | 18% | 36% |
| Parents | €62,110 | 30% | 40% |
| Other (siblings, friends, etc.) | €2,769 | 30% | 40% |
Figures for 2026. The parental exemption is generally shared if both parents inherit from the same deceased person.
The applicable exemption is deducted before the relevant tax rates are applied. A spouse or qualifying partner may therefore inherit a substantial amount without paying inheritance tax, while a sibling or unrelated beneficiary receiving the same amount could face a considerably higher liability.
Special rules may apply where a spouse or recognised tax partner receives a qualifying survivor pension:
- The qualifying pension entitlement is generally not directly subject to inheritance tax.
- Its value may reduce your inheritance tax exemption under the pension imputation rules.
- The allowance cannot be reduced below the applicable statutory minimum.
Disabled children who meet the relevant conditions qualify for a higher exemption of €78,671. Biological and adopted children are generally treated equally, while stepchildren and qualifying foster children may also benefit from the child exemption.
For deaths occurring in 2026, the inheritance tax return must generally be filed within 20 months of the date of death. You may do so online through a self-service portal or in paper form where applicable, including if you live abroad and cannot access the online service.
How Does Gift Tax Work in the Netherlands?
Gift tax in the Netherlands operates independently of inheritance tax, although through similar relationship-based rules. The tax ranges between 10% and 40% of the value of the transfer that exceeds the applicable exemptions.
The following annual gift tax exemptions apply in 2026:
- Children: €6,908 annually for gifts from parents
- Children aged 18–40: One-off €33,129 exemption, which can increase to €69,009 for qualifying expensive education, subject to the applicable conditions
- Other recipients: €2,769 annually
The age condition for the increased exemption may also be satisfied by the child’s partner. The increased exemption replaces the annual exemption for that year rather than being added to it.
Eligibility also depends on whether a higher exemption has previously been used. Gifts from parents are generally combined for the purpose of calculating the available exemption.
Gift tax rates generally follow the same structure as inheritance tax rates:
| Relationship to the Donor | Tax Rate (on excess up to €158,669) | Tax Rate (on excess over €158,669) |
|---|---|---|
| Partner or child | 10% | 20% |
| Grandchild and further descendants | 18% | 36% |
| Other recipients | 30% | 40% |
These rates apply where a taxable gift arises. Transfers between qualifying partners may be treated differently under Dutch gift tax rules.
Unlike the UK’s approach to certain lifetime gifts, the Netherlands provides annual exemptions for qualifying transfers without relying on a cumulative lifetime allowance in the same way. For families transferring wealth over several years, these exemptions may support a gradual gifting strategy, although the donor’s residence, the recipient’s circumstances and potential UK IHT implications must also be considered.
Gifts made shortly before death may also be treated as part of the inheritance under Dutch rules. For UK expatriates, the long-term residence regime can affect how lifetime gifts are treated for UK IHT purposes.
Dutch gift tax may still apply when the recipient lives outside the Netherlands. If the donor relocates from the Netherlands, its continued applicability depends partly on Dutch nationality and previous residence:
| Nationality | Gift Tax Applicability After Relocation |
|---|---|
| Dutch national | Generally within 10 years of relocation |
| Non-Dutch national | Generally within 1 year of relocation |
These deemed-residence provisions concern the donor’s status and should not be confused with the separate rules governing Dutch inheritance tax.
Could Your UK and Dutch Assets Be Exposed to Inheritance Tax in Both Countries?
How Does the Dutch Inheritance Tax Interact With UK IHT?
Dutch inheritance tax and UK IHT can both apply where the deceased was resident or deemed resident in the Netherlands and remained within the scope of UK IHT under the long-term residence rules or through UK-situated assets. The resulting liability depends on residence history, asset ownership and available double taxation relief.
When Does Dutch Inheritance Tax Apply to UK Expats?
The Netherlands generally bases inheritance tax on the deceased’s residence status. If you are a Dutch tax resident at the time of death, inheritance tax applies to your worldwide estate. If you are neither resident nor deemed resident, Dutch inheritance tax generally does not apply, even if you hold substantial Dutch assets.
Dutch asset ownership alone does not ordinarily create an inheritance tax liability where the deceased was neither resident nor deemed resident.
An important exception is the deemed-residence rule for Dutch nationals. If you are a Dutch national when you leave the Netherlands, you may remain within the scope of Dutch inheritance tax for ten years after departure.
The separate one-year deemed-residence rule for certain former residents who are not Dutch nationals applies to gift tax, not inheritance tax.
Your Dutch residence status depends on the relevant legal rules and your individual circumstances. For UK expats who have acquired Dutch nationality or maintain connections with both countries, these distinctions can affect the scope of their estate’s tax exposure.
The UK’s Long-Term Residence Regime
Relief from Dutch inheritance tax as a result of non-residency does not exempt you from UK IHT, which has operated under a residence-based framework since 6 April 2025. Specifically, the UK utilises the long-term residence (LTR) regime under which worldwide estates of long-term residents are generally within the scope of IHT.
You are generally considered an LTR if you have been a UK tax resident for at least ten of the previous 20 UK tax years. Ten consecutive years of UK residence can satisfy this test, but it is not a separate requirement.
Unlike the Netherlands, the UK can also tax certain UK-situated assets. Being outside the LTR regime therefore does not necessarily remove UK IHT exposure, subject to applicable exemptions, reliefs and treaty provisions.
Leaving the UK does not necessarily remove foreign assets from the scope of IHT immediately. Rather, you may encounter a “tail” period during which your worldwide estate can remain within the scope of UK IHT regardless of your current residence.
The tail period generally depends on the number of years you were UK resident within the relevant 20-year period:
| Number of UK Residency Years | IHT Tail Period |
|---|---|
| 10–13 years | 3 years |
| 14 years | 4 years |
| 15 years | 5 years |
| 16 years | 6 years |
| 17 years | 7 years |
| 18 years | 8 years |
| 19 years | 9 years |
| 20 years | 10 years |
These are the general post-departure rules. Transitional provisions may apply to individuals who were non-UK residents in 2025/26, depending on their domicile status under the previous rules. These provisions can produce a different result from the standard three-to-ten-year tail.
Your UK residence history should therefore be reviewed before relocating to the Netherlands or planning a return to the UK, particularly where the LTR tail period may affect your estate.
Double Taxation Prevention
Because the UK and the Netherlands apply different inheritance tax rules, your estate may be subject to tax under both systems.
A Dutch resident who also remains a UK long-term resident may have worldwide assets subject to inheritance tax in both countries.
The UK generally charges IHT at 40% on the taxable estate above the available allowances, while the Netherlands calculates inheritance tax separately for each beneficiary. The combined outcome depends on the applicable exemptions, asset classification and any available double taxation relief. It should not be assumed that UK IHT is always paid first or that Dutch inheritance tax is necessarily calculated on the amount remaining after UK tax.
By contrast, a UK expat who leaves the Netherlands without Dutch nationality may cease to be within the scope of Dutch inheritance tax once they are no longer Dutch resident. UK IHT exposure may nevertheless continue under the LTR rules, while UK-situated assets can remain within scope even after LTR status ends.
To address double taxation in cases where both jurisdictions may tax the same inheritance, the UK and the Netherlands entered into an estate tax treaty. The treaty addresses several issues, including:
- Allocating taxation rights between jurisdictions for relevant assets
- Outlining credit relief mechanisms available in one country for tax paid in another
- Establishing rules for determining the deceased’s treaty status where connections exist with both jurisdictions
Although the treaty can reduce or eliminate double taxation, it should not be considered a universal protection mechanism available by default. The relief available depends on factors including residence history, asset classification and valuation. These must be reviewed to establish whether a full or partial credit is available.
For UK expatriates with assets in both countries, Titan Wealth International can help assess how inheritance tax exposure, treaty provisions and existing estate arrangements fit within your wider cross-border estate plan.
Estate Planning Considerations for UK Expats in the Netherlands
Regular Estate Reviews
If you live in the Netherlands and hold assets in the UK or elsewhere, reviewing your estate can help establish where inheritance tax liabilities may arise. Start by identifying three categories of assets:
- UK assets
- Dutch assets
- International or globally mobile assets
Each category may be treated differently according to your residency history, asset ownership and applicable tax rules. Review your Dutch residency and nationality in the context of inheritance tax applicability, and assess your UK residency history against the LTR requirements.
Your estate review should also cover jointly owned property, trusts and investment structures, as ownership arrangements may affect their treatment under the relevant tax and succession rules.
An early review may provide more scope to consider lifetime gifts and changes to your estate structure. Dutch annual gift exemptions may support regular lifetime transfers, but the UK treatment must also be considered, including the seven-year rule for certain gifts and the rules concerning retained benefits.
Review your estate plan periodically, particularly when your residence, asset ownership or family circumstances change.
Coordination of Pension Arrangements
Pensions and death benefits may represent a substantial part of your wealth, but their inheritance tax treatment can differ between the UK and the Netherlands. The structure of the arrangement and the member’s residence history are therefore important considerations.
For instance, if your residency plan indicates that you will not be a UK LTR at the time of death, you may wish to review whether retaining your UK pension or transferring it to a Dutch qualifying recognised overseas pension scheme (QROPS) is appropriate.
From 6 April 2027, most unused pension funds and pension death benefits will be included in the deceased’s estate for UK IHT purposes under the relevant statutory rules. However, transferring a pension overseas does not automatically remove it from the scope of IHT.
Before considering transferring your pension to the Netherlands, you should assess the receiving scheme’s eligibility, potential overseas transfer charges, the loss of existing pension benefits and the tax treatment in both countries. If you remain a UK LTR, foreign pension arrangements may also fall within the scope of UK IHT.
Pension decisions should therefore form part of your wider estate plan, rather than being considered in isolation.
Wills and Estate Administration
Wills and beneficiary nominations also need to be reviewed as part of a cross-border estate plan. Understanding the differences between UK and Dutch inheritance laws is critical to making such decisions.
Dutch law includes forced heirship protections for children, whereas England and Wales generally allow broader testamentary freedom. Under the EU Succession Regulation, British nationals may generally elect the law of their relevant UK jurisdiction to govern their succession, subject to the applicable conditions.
This choice can affect how Dutch succession rules apply, but it does not automatically change the inheritance tax treatment of your estate. Any election should be reviewed in light of your nationality, residence and family circumstances.
Dutch law generally requires separate testamentary instruments rather than a joint will made by two individuals. Existing UK wills may still be recognised, depending on the applicable rules, so they should be reviewed before new documents are prepared.
Although a single global will may be enforceable in both the UK and the Netherlands, separate local wills may be appropriate in some circumstances. Distinct wills addressing each country’s assets can help with estate administration, although they must be drafted carefully so that one will does not accidentally invalidate the other.
Complimentary UK-Netherlands Inheritance Tax Planning Consultation
If you hold assets in both the UK and the Netherlands, your estate plan should reflect the inheritance tax rules in each country. Your residence history, lifetime gifts, pension arrangements and beneficiary provisions can all influence how your wealth passes to future generations.
In a complimentary introductory consultation with Titan Wealth International, you will:
- Review how your UK and Dutch assets, residency history and beneficiary arrangements may affect your exposure to inheritance tax in both jurisdictions.
- Understand how Dutch inheritance and gift tax exemptions, UK IHT rules and potential double taxation relief may influence your estate planning.
- Explore how Titan Wealth International can help you coordinate your pensions, investments, gifting arrangements and wider estate structures as part of a cross-border wealth plan.
Key Takeaway
Dutch inheritance tax is calculated separately for each beneficiary, with exemptions and rates determined by their relationship to the deceased. Gift tax provides a separate framework for lifetime transfers, while UK inheritance tax may continue to apply to certain assets or worldwide estates under the long-term residence rules.
For UK expatriates with assets in both countries, effective estate planning requires an understanding of Dutch residence rules, UK IHT exposure and any available double taxation relief. Pensions, lifetime gifts and asset ownership should also be reviewed together, particularly when your residence or family circumstances change. Titan Wealth International can help you coordinate these considerations as part of your wider cross-border estate plan.
This article is provided for general information only and reflects our understanding at the date of publication. It does not constitute personalised financial, investment, tax or legal advice and does not take account of your individual circumstances. Tax, legal and regulatory treatment varies between jurisdictions, and you should seek professional advice appropriate to the countries in which you may have liabilities. Titan Wealth International accepts no liability for any direct or indirect loss arising from reliance on this information, or for any errors or omissions.