Perspectives

Top 7 Places to Hold Property for Estate Planning in 2026

4 min read

Every estate pays one of two prices: the tax, or the planning. The cheapest planning is done a decade before anyone needs it.

Abhii DabasByAbhii Dabas

Where can property pass to the next generation with the least inheritance tax in 2026? The UAE, Singapore, Australia, New Zealand, and Hong Kong levy no inheritance tax at all, Portugal exempts spouses and children, and Canada charges none (though capital gains apply at death). At the other end, Japan reaches 55%, South Korea 50%, France 60% for non-family, and the UK 40% above a frozen £325,000 band.

One rule decides most outcomes: tax follows the asset’s location as well as the owner’s residence. Here are the seven cleanest bases, and the trap attached to each zero.

2026 in four numbers

FigureWhat it measures
55%Japan’s top inheritance tax rate, the world’s highest
40%UK inheritance tax above the £325,000 nil-rate band
0%Inheritance tax in the UAE, Singapore, Australia, NZ, and others
US$60kUS estate-tax exemption for non-residents’ US-situs assets

Sources: PwC / OECD data, HMRC, PwC data, 2026 tax guides.

The seven, in order

1. United Arab Emirates

No inheritance tax, no personal income tax on PwC data, and a deep prime market in Dubai. The zero applies at the asset’s end; a UK-scoped or US-scoped owner may still owe at home.

2. Singapore

No estate duty since 2008, top-tier title security, and Asia’s deepest prime market. The preservation-and-succession pairing in one jurisdiction.

3. Australia

No inheritance tax since 1979. Capital gains rules apply to inherited assets when later sold, so the zero is at death, not forever.

4. New Zealand

No inheritance tax, second-safest country on the 2026 Global Peace Index, and an investor residency route via Active Investor Plus.

5. Hong Kong

Estate duty abolished, bilingual legal infrastructure, and direct pathways for family succession planning in Asia’s traditional wealth hub.

6. Portugal

Spouses and children inherit Portuguese assets with zero tax, which quietly strengthens the retirement-and-golden-visa case for direct-line family wealth.

7. Canada

No inheritance tax, but death triggers a deemed disposition for capital gains, so the estate pays on accrued growth. Clean, but not free.

On INTRIC now — Residences on INTRIC are open to enquiry straight from this page.

The 2026 picture side by side

Jurisdiction2026 headline positionThe note that matters
JapanUp to 55%The world’s highest top rate
South KoreaUp to 50%Among the heaviest regimes globally
France5-45% direct line; 60% non-familySmall allowances outside the direct line
United Kingdom40% above £325,000Residence-based scope from April 2025; business and agricultural reliefs capped from April 2026
Germany7-50% by tax classRelationship and amount drive the rate
United States40% top federal rate above a multi-million exemption2026 guides report a US$15m exemption made permanent by 2025 legislation; non-residents face tax above just US$60,000 of US-situs assets
UAE, Singapore, Australia, NZ, Hong KongNo inheritance taxCanada also levies none but applies capital gains via deemed disposition at death; Portugal exempts direct-line heirs

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.

Estate planning is preservation’s final chapter

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.

On INTRIC now — Still open on INTRIC — every one of these answers enquiries directly.

The three traps

  • Situs: a UK property stays in UK IHT scope whoever owns it, and non-residents face US estate tax above just US$60,000 of US-situs assets.
  • The owner’s regime travels: the UK now scopes worldwide estates by residence (ten of the last twenty years, with a tail after leaving).
  • Envelopes are dead: offshore company ownership stopped sheltering UK homes in 2017 and still triggers ATED; plan with qualified advice, not structures from 2015.

Every estate pays one of two prices: the tax, or the planning. The cheapest planning is done a decade before anyone needs it.

Read the full intelligence report

“The last tax bill: estate planning and inheritance tax in 2026” goes deeper on the full 2026 rate map from 0% to 55%, the situs traps, and the residence rules that changed in the UK. Access it through the free Explorer tier at intricglobal.com/en/subscribe.

Frequently asked questions

Which countries have no inheritance tax in 2026?

The UAE, Singapore, Australia, New Zealand, and Hong Kong among others, with Portugal exempting direct-line heirs and Canada applying capital gains rather than inheritance tax at death.

Which country has the highest inheritance tax?

Japan, at up to 55%, followed by South Korea at 50%. France charges up to 60% on non-family transfers.

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

Yes, on US-situs assets above an exemption of just US$60,000, one of the most commonly missed cross-border traps.

What changed in UK inheritance tax recently?

Scope became residence-based from April 2025, covering worldwide estates after ten years of UK residence in the last twenty, and full business and agricultural reliefs were capped from April 2026.

This article is information only and is not tax, legal, immigration, or investment advice. Rules change frequently and vary by circumstance; take qualified professional advice. Property values can fall as well as rise and capital is at risk. Figures are rounded and attributed to PwC, HMRC, the OECD, and 2026 international tax guides.

Author
Abhii Dabas
Abhii DabasFounder & CEO, INTRIC Global

Abhii Dabas is the Founder and CEO of INTRIC Global, the cross-border property intelligence platform for serious investors. He advises high-net-worth buyers on international real estate strategy and has evaluated residential markets across more than 40 countries.

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