Contents
Japan taxes up to 55%, France 45%, the UK 40%, while the UAE, Singapore and Malaysia levy nothing. Where an estate is taxed matters as much as where you live.
Inheritance tax ranges from zero to 55% depending on the country. Among the countries we compare, Japan has the highest top rate when children inherit, at 55%, followed by South Korea at 50%, France at 45% for children, and the UK and US at 40%. At the other end, the UAE, Singapore, Malaysia, Australia, New Zealand and Cyprus have no inheritance tax at all. Vietnam charges 10% personal income tax on certain inherited assets above VND 20 million under a new law in force from 1 July 2026. For families with assets in several countries, where the estate will be taxed matters as much as where they live.
Source: PwC Worldwide Tax Summaries (2026 updates); Vietnam PIT Law No. 109/2025/QH15; OECD, Inheritance Taxation in OECD Countries (2021)
Many Vietnamese families plan their wealth in a familiar order: earn, buy property, invest, and at some point "pass it on to the children". When everything sits in Vietnam, that last step is fairly simple. Once the family owns an apartment in Australia, shares in the US or has children settled in Britain, the handover can run into tax systems whose top rate takes up to half the estate.
This piece lines the numbers up across five charts and a comparison table, then flags a few points that often get missed. Every figure comes from public sources, mainly PwC Worldwide Tax Summaries updated in 2026 and Vietnamese legislation.
From 55% to Zero: A Very Uneven World
According to the OECD's 2021 study of inheritance taxation, 24 of its then 37 members levied inheritance or estate taxes, yet on average these raised only about 0.5% of total tax revenue. For governments, inheritance tax is small change. For an individual family, it can be the largest single tax bill of their lives.
The headline rate is only the starting point. The US charges 40%, but only on estates above a USD 15 million per-person exemption from 2026. The UK charges 40% above a GBP 325,000 nil-rate band, frozen until April 2031. Italy charges just 4% to spouses and children, and only above EUR 1 million per heir. Spain's state scale reaches 34%, but many autonomous communities have introduced substantial reliefs, so the real figure depends on the region.
Portugal deserves a closer look. It has no inheritance tax as such; instead it levies a 10% stamp duty on gratuitous transfers. Spouses, descendants and ascendants, however, are fully exempt from that stamp duty.
Inside the Brackets: France and Japan
Progressive scales show that the 45% or 55% headline applies only to the top slice. In France, each child first deducts EUR 100,000, and tax then rises through seven brackets.
For governments, inheritance tax is small change. For an individual family, it can be the largest single tax bill of their lives.
View data table
| Item | Value |
|---|---|
| ≤8 | 5% |
| 8–12 | 10% |
| 12–16 | 15% |
| 16–552 | 20% |
| 552–903 | 30% |
| 903–1,806 | 40% |
| Above 1,806 | 45% |
Source: Barème des droits de succession en ligne directe 2026, via Weblex; PwC Worldwide Tax Summaries – France
Japan's scale has eight brackets, from 10% on the first JPY 10 million to 55% above JPY 600 million. What many foreigners miss is the scope: according to PwC, a foreign national's overseas assets can be exempt if they have lived in Japan for less than ten of the last 15 years on a work-type visa. Stay longer, or hold permanent residence, and worldwide assets can come into scope.
View data table
| Item | Value |
|---|---|
| ≤10 | 10% |
| 10–30 | 15% |
| 30–50 | 20% |
| 50–100 | 30% |
| 100–200 | 40% |
| 200–300 | 45% |
| 300–600 | 50% |
| Above 600 | 55% |
Source: PwC Worldwide Tax Summaries – Japan, Individual: Other taxes (reviewed August 2026)
The Same EUR 2 Million, Five Different Outcomes
To make this concrete, imagine one child inheriting EUR 2 million, with the whole amount falling within each country's tax net. We apply the published scales without any special reliefs.
The gap can exceed EUR 600,000. In France, after the EUR 100,000 allowance, the child owes about EUR 617,000 – nearly 31% of the inheritance. In Greece, the closest relatives receive the first EUR 150,000 tax-free, then pay 1%, 5% and 10% by bracket, about EUR 156,500 in total. Italy takes EUR 40,000; Portugal and Cyprus take nothing. This is an illustration: the real bill depends on residence, where the assets sit and any tax treaty.
Vietnam: 10%, but Not on Everything
Vietnam's Personal Income Tax Law No. 109/2025/QH15, in force from 1 July 2026, keeps a 10% rate on inheritance income but raises the threshold to VND 20 million per receipt. Under the text of the law, taxable inheritances are securities, capital interests in businesses, real estate and other assets that require ownership or use registration.
Real estate passed within the family is exempt. Article 4 exempts real estate inherited between spouses, parents and children (including adopted children and children-in-law), grandparents and grandchildren, and siblings. For most Vietnamese families, then, the domestic inheritance burden is light. It gets complicated only when assets or heirs are abroad.
Who Gets Taxed Depends on Who, Where and How Long
Each country uses a different key to decide whether it taxes a transfer: the deceased's residence, the heir's residence, or the location of the asset. The table summarises a few of the main rules.
Canada treats the deceased as having sold everything immediately before death – an inheritance tax by another name.
| Country | Who or what is taxed | Watch out for |
|---|---|---|
| United Kingdom | Residence-based from 6 April 2025: people resident 10 of the past 20 years are taxed on worldwide assets | Exposure can last up to 10 years after leaving; UK property is always in scope |
| United States | US-domiciled: worldwide assets; others: US-situs assets | USD 15m exemption per person from 2026 (OBBBA) |
| France | Deceased resident in France, or heir resident 6 of the past 10 years | French property is always in scope |
| Japan | Depends on visa type and years of residence (10-of-15 test) | Japanese assets are always in scope |
| Canada | No inheritance tax | Deemed disposal at death; accrued gains taxed as income |
| Vietnam | Heir: 10% above VND 20m per receipt | Real estate between close relatives exempt |
Canada and New Zealand both have "no inheritance tax", but they differ. New Zealand genuinely doesn't tax the transfer. Canada treats the deceased as having sold everything immediately before death, so accrued capital gains are still taxed as income – an inheritance tax by another name.
A practical strategy for Vietnamese investors
Map assets before drafting a will. List where each asset is, whose name it's in and what kind it is. One family can face three tax systems if it owns a house in Australia, US shares and has children resident in the UK.
Think about where new assets sit. When buying property abroad, factor in the cost of passing it to the next generation, not just the yield. Jurisdictions with no inheritance tax, such as Cyprus, the UAE or Malaysia, make that step far simpler.
Watch the whole family's residence clock. In the UK, France and Japan, years of residence set the scope of tax. A child who studies abroad and stays on to work can unintentionally pull family wealth into that country's net.
Don't decide alone. Tax treaties, domicile rules and civil inheritance law differ in every country. A sound plan needs lawyers and tax advisers at both ends.
Frequently asked questions
Which country has the highest inheritance tax?
Among major economies, Japan has the highest rate at 55% above JPY 600 million, followed by South Korea at 50%. France applies up to 60% to unrelated heirs.
Do Vietnamese heirs pay tax on property inherited from their parents?
Under PIT Law 109/2025/QH15, real estate inherited between parents and children is exempt from personal income tax. Other assets such as securities or capital interests are taxed at 10% above VND 20 million.
Is this tax advice?
No. This is a summary of public information for reference only; rules change often and depend on each family's circumstances. Please consult a licensed lawyer or tax professional before making decisions.
NAC strategic insight
Inheritance tax is usually the last thing people think about when buying abroad, yet it can take the most. The same assets can reach the children almost intact or lose nearly a third, depending on where they sit and where the family lives.
NAC helps Vietnamese families ask this question up front: choosing markets, residence routes and ownership structures with the next generation in mind, working alongside partner lawyers and tax advisers in each country. If you'd like to review your family's asset map, book a consultation with NAC.
Sources
- PwC — Worldwide Tax Summaries: Inheritance and gift tax rates (2026)
- OECD — Inheritance Taxation in OECD Countries (2021)
- Vietnam Personal Income Tax Law No. 109/2025/QH15 (2025)
- Weblex — Tarifs des droits de succession 2026 (2026)
- PwC — Worldwide Tax Summaries: United Kingdom, Individual – Other taxes (2026)
