Estate Planning and Inheritance Tax in 2026

Headline rates for 2026, by jurisdiction.

Which countries have the highest and lowest inheritance taxes in 2026?

Japan is the ceiling at 55%; a long list of major jurisdictions sits at zero. Rates alone mislead without the reliefs: spouse exemptions are often unlimited, direct-line allowances vary enormously, and several zero-IHT countries tax death another way. On PwC’s Worldwide Tax Summaries, the gap between the heaviest and lightest regimes is wider than for almost any other tax a property owner will meet.

Sources: PwC Worldwide Tax Summaries, OECD data, HMRC, and 2026 international tax guides. Reliefs, treaties, and forced-heirship rules vary by circumstance; take qualified advice.

INTRIC READ

The mistakes that cost real money.

Can moving abroad remove inheritance tax on property?

Only partly, because the asset’s location keeps its own claim. Residence planning changes the estate-wide picture, but immovable property generally stays in the tax net of the country it stands in. A family can leave a high-tax country and still owe that country’s inheritance tax on the home they kept there.

• A UK property sits in UK IHT scope regardless of the owner’s residence, and offshore company ownership stopped sheltering it in 2017 while still triggering ATED.
• Non-residents holding US real estate or US shares face US estate tax above just US$60,000 of US-situs value, a routinely missed exposure.
• The UK’s April 2025 reform scopes the worldwide estate once someone has been UK resident ten of the last twenty years, and the exposure lingers for a period after leaving.
• From April 2026, full UK business and agricultural property reliefs are capped, exposing larger family business and farm estates to an effective charge of up to around 20% above the cap.
• Double-tax treaties on inheritance are rarer than income-tax treaties; cross-border estates can be taxed in more than one country without one.

And what each zero really means.

Which property markets let wealth pass with no inheritance tax in 2026?

The UAE, Singapore, Australia, New Zealand, and Hong Kong head the list, with Portugal clean for direct-line heirs. The zeros are not identical. Canada levies no inheritance tax but treats death as a disposal for capital gains. Portugal’s exemption covers spouses and children.

And a zero in the asset’s country does not switch off the owner’s home-country regime: a UK-scoped or US-scoped owner can owe tax on a Dubai apartment at home. The clean pass requires both ends of the wire to be clean, which is a residence question as much as a market question.

The intent behind the intent.

How does estate planning combine with the other buyer intents?

It is the reason preservation buyers hold what they hold, where they hold it. The London purchase made for sterling safety and clean succession structures, the Dubai purchase made where nothing is due at death, the residence chosen a decade early: estate planning is rarely the stated reason for a purchase, and very often the real one.

Intric maps this intent alongside residency implications, preservation characteristics, and education access across more than 70 markets on a comparable basis, so a family can see where a single purchase satisfies the most of what it is actually trying to do. The intelligence layer surfaces the comparison and the trade-offs. The judgment, and the decision, stay with the investor and their advisers.

For HNW investors and families. Intric is a private, invitation-only network for cross-border residential investment across 70+ markets. Members access comparative intelligence first, and specific opportunities second. Explore the free Explorer tier at intricglobal.com/en/subscribe.

Which country has the highest inheritance tax in 2026?

Japan, with a top rate of 55%, followed by South Korea at 50%. France reaches 45% for direct heirs and 60% for non-family transfers.

Which countries have no inheritance tax in 2026?

The UAE, Singapore, Australia, New Zealand, Hong Kong, and Sweden among others, with Portugal exempting direct-line heirs. Canada levies none but applies capital gains through deemed disposition at death.

What changed in UK inheritance tax for 2026?

Scope became residence-based from April 2025, covering worldwide estates once someone has been UK resident ten of the last twenty years, and from April 2026 full business and agricultural property reliefs are capped, per HMRC and 2026 guides.

Do non-residents pay US estate tax on US property?

Yes. Non-resident aliens face US estate tax on US-situs assets, including real estate and US shares, above an exemption of just US$60,000, a commonly missed trap.

Does owning UK property through an offshore company avoid inheritance tax?

No. That protection ended in 2017, and enveloped structures still trigger ATED. Structures should be reviewed with qualified UK tax advice.

Sources and further reading: PwC Worldwide Tax Summaries (inheritance and estate tax by jurisdiction); HMRC (UK IHT reform, reliefs, and ATED); OECD (inheritance taxation data); IRS (US estate tax for nonresidents).

This report is provided for information only and is not tax, legal, immigration, or investment advice. Rules change frequently and vary by individual circumstance; take qualified professional advice before acting. Property values can fall as well as rise and capital is at risk. Past performance is not a guide to future performance. Figures are rounded and attributed to the named third parties above. A UK property confers no residency or visa right.