Countries With No Inheritance Tax: A Guide for UK Expats

This distinction is especially important for UK expatriates. Moving to a country with no inheritance tax does not necessarily remove exposure to tax on your worldwide estate. Your UK residence history, the location of your assets and the tax and succession rules of other jurisdictions can all affect the eventual position.

This guide compares countries with no inheritance tax, jurisdictions where other taxes can arise on death or a later disposal, and countries offering substantial exemptions for close family members. It also explains why internationally mobile families should consider these rules as part of a coordinated cross-border estate plan.

Inheritance Tax vs Estate Tax: What Is the Difference?

Inheritance tax and estate tax both apply to wealth transfers on death, but the way they are calculated and charged varies significantly.

Broadly, inheritance tax is generally charged by reference to the assets received by a beneficiary. The amount payable often depends on:

• The beneficiary’s relationship with the deceased: Spouses and direct descendants often qualify for exemptions or reduced tax rates, whereas unrelated parties or more distant relatives may be subject to higher rates and fewer reliefs.
• The value of the inheritance: Portions exceeding established statutory thresholds may be taxed at progressively higher marginal rates.
• The country’s tax rules: Specific allowances, deductions, and applicable rates can vary materially depending on the jurisdiction administering or taxing the estate.

Estate tax is generally levied on the deceased person’s estate before the assets are distributed to beneficiaries.

These distinctions are useful when comparing countries, although the terminology and legal incidence of taxes on death vary between jurisdictions.

Some countries impose neither inheritance nor estate tax but instead utilise alternative mechanisms that can tax wealth or assets on death or at a later date, such as:

• Capital gains tax (CGT), where death may be treated as a deemed disposal of assets, or where gains become taxable when inherited assets are later sold
• Gift taxes, which can apply to certain lifetime transfers
• Stamp duties or transfer taxes, which may apply when inherited property or other assets change ownership
• Succession or probate charges, which may increase the overall cost of administering an estate, even where no inheritance tax exists

Expats must understand that relocating to a country with no inheritance tax does not automatically result in tax-free estate planning. The tax position can depend on residence history, asset location, applicable succession law and continuing tax connections with other jurisdictions.

Which Countries Do Not Have Inheritance Tax?

Countries that do not currently impose a general inheritance or estate tax include the UAE, Cayman Islands, the Bahamas, Singapore and Hong Kong. However, the absence of a direct inheritance tax does not mean an estate is necessarily free from tax, duties or succession requirements.

Several countries do not levy IHT or estate tax, making them attractive destinations for high-net-worth (HNW) individuals seeking a more favourable tax environment. They include:

• The United Arab Emirates (UAE)
• Cayman Islands
• Bermuda
• Bahamas
• Singapore
• Hong Kong

However, local succession laws, probate procedures, stamp duties, and foreign tax obligations can still affect the structuring of asset distribution to beneficiaries.

What Does ‘No Inheritance Tax’ Actually Mean?

The term can describe several different tax positions. A jurisdiction may have no beneficiary-level inheritance tax, no estate tax, an exemption for certain beneficiaries, or no direct tax on death while still imposing capital gains tax, stamp duty, transfer charges or other liabilities.

For internationally mobile families, the distinction matters. The absence of a tax formally described as inheritance tax does not establish how an estate will ultimately be taxed or administered.

The United Arab Emirates (UAE)

The UAE does not impose inheritance tax or estate tax. The absence of IHT can apply to assets such as:

• Cash
• Investments
• Business interests
• Real estate

Still, a tax-free environment does not eliminate the need for robust estate planning. The succession and probate rules applying to UAE assets can depend on the individual’s circumstances, the nature and location of the assets, and the estate-planning arrangements put in place.

Expats should also consider whether they need a legally enforceable will that complies with the appropriate UAE rules and registration procedures. The succession rules that apply in the absence of effective estate planning may not align with an individual’s intentions.

This risk compounds when assets are held across multiple jurisdictions, as conflicting succession regimes can give rise to legal uncertainty, administrative delays, and unintended distributions.

Cayman Islands

With no IHT or estate tax, the Cayman Islands is one of the jurisdictions often considered by internationally mobile individuals when planning the ownership and succession of wealth.

Although beneficiaries are not subject to Cayman inheritance tax, administering a Cayman estate can still require a formal probate process. Executors or administrators may need the appropriate authority from the Grand Court of the Cayman Islands before Cayman property, bank accounts, or company shares can be distributed.

For individuals with Cayman assets, maintaining an up-to-date will and ensuring that it works alongside wills or estate-planning arrangements in other countries is important. Cross-border succession rules can affect how a foreign will is treated and how efficiently Cayman assets can be administered.

Bermuda

Bermuda does not levy a tax formally called inheritance tax. However, this should not be confused with an absence of tax on an estate.

Stamp duty can apply to a deceased person’s net Bermuda estate. The charge is calculated after applicable deductions and exemptions and uses progressive rates, which can reach 20% on the highest band. Certain amounts, including qualifying benefits passing to a surviving spouse, may be deductible, and specific exemptions can also apply.

Consequently, Bermuda should not be treated as completely free of death-related taxation simply because it has no tax called inheritance tax.

Bermuda succession laws are based on English common law and are supplemented by local legislation. Testamentary freedom is broadly respected, allowing individuals to leave their estate through a valid will that meets the relevant formalities.

However, that freedom is not absolute. Spouses and certain dependants may be able to apply to the court for financial provision where the will or the rules of intestacy do not make adequate provision for them.

In the absence of a valid will, Bermuda’s intestacy rules determine the distribution of the deceased’s estate, with the precise division depending on the surviving family members.

Bahamas

The Bahamas imposes no IHT or estate tax on individuals.

However, the absence of direct inheritance taxation does not remove administrative formalities. A formal probate or administration process may be required before executors or administrators can deal with Bahamian assets, including:

• Transferring legal title to real property
• Updating company share registers
• Releasing funds from Bahamian bank accounts

In the absence of a valid will, Bahamian intestacy rules determine how the estate is distributed.

For expats, the more important question is often whether assets or the deceased remain exposed to tax in another jurisdiction despite the absence of Bahamian inheritance tax.

Singapore

Singapore abolished estate duty for deaths occurring on or after 15 February 2008. Consequently, Singapore does not impose a direct estate or inheritance tax on assets passing to beneficiaries.

Despite the absence of IHT, succession planning remains important. Executors may need to obtain probate or letters of administration before administering an estate, and legal and administrative costs can still arise.

For expats in Singapore, cross-border assets may remain subject to inheritance or estate taxation in another jurisdiction, making coordinated international estate planning important.

Hong Kong

Hong Kong abolished estate duty in 2006. Today, the territory does not impose inheritance or estate tax.

The absence of estate duty does not remove the need for succession planning. Expats with Hong Kong assets should consider having a valid will that works alongside their arrangements in other jurisdictions.

Without a valid will, Hong Kong assets are distributed according to the applicable intestacy rules. This can produce a different result from the distribution the deceased would have chosen, particularly where there are unmarried partners or complex family arrangements.

Which Inheritance Tax-Free Countries Still Tax Wealth Transfers?

Many countries do not have a formal inheritance or estate tax, but tax can still arise either on death or when inherited assets are later sold or generate income.

The important distinction is timing. In Canada, for example, death itself can trigger a deemed disposition. In Australia and New Zealand, the receipt of inherited property will not generally create the same immediate charge, but tax can arise later. For an expat with assets in several countries, those differences can materially affect both liquidity and the administration of the estate.

Which European Countries Have No Inheritance Tax But May Impose Other Obligations?

Several European countries have abolished inheritance tax but impose alternative succession-related costs and obligations. These can include tax on future disposals, property charges, land registration fees, notarial costs and mandatory reporting requirements.

These rules vary between jurisdictions, as follows:

This is why a list of countries with no inheritance tax needs to be read with care. The absence of a tax bearing that name does not necessarily mean that an estate can be administered or assets transferred without tax, fees or reporting requirements.

Which Countries Have Inheritance Tax But Offer Generous Family Exemptions?

Some countries continue to levy inheritance, succession or estate taxes but provide substantial exemptions for spouses, children, and other close family members. The availability of these exemptions usually depends on the relationship between the deceased and the beneficiary, the value of the estate, the location of the asset, and the tax status of the individuals involved.

Jurisdictions that offer significant family exemptions include:

• Monaco
• Portugal
• Italy
• The United Kingdom
• France
• Germany
• The United States

Monaco

Monaco is sometimes described as an inheritance tax-free jurisdiction because of its treatment of close family members, but this description is misleading.

Succession duties apply to assets situated in Monaco, with the rate determined by the relationship between the deceased and the beneficiary. Spouses and direct descendants are taxed at 0%, while other beneficiaries can face higher rates:

The duties can apply to Monaco-situs assets regardless of the deceased’s domicile, residence or nationality, subject to applicable treaty provisions.

Portugal

Close family members, including spouses or de facto partners, descendants and ascendants, are exempt from the 10% stamp duty that would otherwise apply to qualifying gratuitous transfers.

However, where Portuguese real estate is involved, a separate 0.8% stamp-duty component can still apply. This is an important distinction for expats who assume that the family exemption makes a Portuguese inheritance entirely tax-free.

Portuguese succession law can also reserve part of an estate for protected heirs, including:

• Spouses
• Children
• Direct ascendants

For internationally mobile families, the succession law governing an estate should be considered separately from its tax treatment.

Italy

Spouses and children each benefit from a €1 million tax-free allowance, with any excess generally taxed at 4%. Siblings have a €100,000 tax-free allowance, with amounts above that threshold generally subject to 6% inheritance tax.

Different rates and allowances apply to more distant relatives and unrelated beneficiaries.

The United Kingdom

Transfers to a spouse or civil partner are generally exempt from UK IHT. However, the exemption can be restricted in certain cross-border circumstances, including where a long-term UK resident transfers assets to a spouse or civil partner who is not a long-term UK resident, subject to the applicable election rules.

Beyond that, the standard nil-rate band (NRB) is £325,000. An additional residence nil-rate band (RNRB), currently up to £175,000, may be available when a qualifying residence passes to direct descendants.

Unused NRB and RNRB can potentially be transferred to a surviving spouse or civil partner. Where all the relevant conditions are satisfied, this can allow a married couple or civil partners to pass up to £1 million without IHT.

For HNW families, however, the £1 million figure should not be treated as an automatic allowance. The RNRB is reduced by £1 for every £2 by which the value of the estate exceeds £2 million. Large estates can therefore lose some or all of the additional residence allowance.

France

Transfers to a surviving spouse or a partner in a PACS are exempt from French inheritance tax. Children benefit from individual allowances, after which progressive inheritance tax rates can apply.

More distant relatives and unrelated beneficiaries receive substantially less favourable treatment, with both allowances and rates depending on their relationship to the deceased.

Germany

Germany provides substantial inheritance tax allowances for close family members. Spouses and registered partners receive a larger allowance than children, grandchildren, more distant relatives and unrelated beneficiaries.

Once the applicable allowance has been used, the tax rate depends on both the value inherited and the beneficiary’s relationship with the deceased.

The United States

The United States needs to be considered differently from jurisdictions that impose only a beneficiary-level inheritance tax.

At federal level, the US imposes an estate tax rather than a general federal inheritance tax. For deaths in 2026, the federal basic exclusion amount is $15 million. Estates above the available exclusion can therefore face federal estate tax.

Separate state rules can also apply. Some states impose inheritance taxes, estate taxes, or both, with their own exemptions and rate structures.

For internationally mobile families, US citizenship, domicile, asset location and applicable estate and gift tax treaties can materially change the position. The position can be very different for non-US citizens who are not US domiciled. For example, federal estate-tax filing can arise for a nonresident non-citizen with more than $60,000 of US-situated assets at death, although treaties and other rules can materially alter the result. The $15 million domestic exclusion should therefore not be assumed to apply in the same way.

Why Moving to a Country With No Inheritance Tax May Not Remove UK IHT Exposure

Choosing a country with no inheritance tax does not guarantee a tax-efficient estate plan. Internationally mobile individuals, particularly those with global assets, multinational family members or long periods of residence in several countries, may have to navigate overlapping legal and tax systems.

Your new country of residence may not levy inheritance or estate taxes, but another jurisdiction can retain taxing rights because of your residence history, citizenship or other relevant status, the location of your assets, or the tax status of your beneficiaries.

The UK’s IHT regime illustrates this.

Since 6 April 2025, the UK has used a long-term residence (LTR) framework for determining when overseas assets fall within the scope of UK IHT, replacing the previous domicile-based framework for these purposes.

Broadly, an individual can become a long-term UK resident after being UK resident for at least 10 of the previous 20 tax years. If an LTR subsequently leaves the UK, overseas assets can remain within the UK IHT framework for between three and ten tax years, depending on the individual’s previous UK residence history.

For example, someone who had been a UK resident for 10 to 13 of the relevant 20 tax years will generally cease to be an LTR after three consecutive tax years of non-residence. The period increases with longer UK residence, up to a maximum ten-year tail. Transitional rules can affect some individuals around the introduction of the regime.

Even where an individual is no longer an LTR, UK-situated assets can remain within the scope of UK IHT.

Trusts also require separate consideration. Under the post-2025 rules, the IHT treatment of overseas trust assets can depend on matters including the settlor’s residence history, when assets were settled and transitional provisions. Moving abroad does not, by itself, establish the tax treatment of an existing trust.

Additionally, every country has its own regulations governing how assets pass to beneficiaries. Even where there is no IHT, there can be other obligations, such as CGT, stamp duty, probate requirements or reporting obligations. Succession law, forced-heirship rules and the recognition and treatment of trusts can also differ significantly between jurisdictions.

Where two countries tax the same assets on death, double-taxation relief or a relevant estate tax treaty may also need to be considered.

To account for these cross-border complexities, a comprehensive estate plan should consider:

• Your residence history and other relevant tax connections
• The location and nature of your assets
• Local succession laws
• Trusts and other estate-planning structures
• The residence or tax status of beneficiaries
• Whether another jurisdiction retains taxing rights over the estate
• Any available treaty or double-taxation relief

Internationally mobile individuals and families may benefit from consulting professional financial, tax and legal advisers in the relevant jurisdictions. Coordinated advice is particularly important before relocating or restructuring an estate, because a change that is effective in one country can have different tax or succession consequences elsewhere.