Inheritance Tax Calculator 2026

Inheritance taxation varies more dramatically between jurisdictions than almost any other form of taxation. While some countries impose no death duties whatsoever, others levy rates exceeding 50% on large estates. Understanding these differences is essential for expatriates, international investors, and anyone with cross-border assets. This guide provides a comprehensive comparison of inheritance tax regimes across ten major jurisdictions for the 2026 tax year.

The fundamental distinction between regimes lies in whether the tax is levied on the estate as a whole (estate tax, as in the USA and UK) or on individual beneficiaries (inheritance tax or succession tax, as in France, Germany, and Spain). Estate tax systems generally offer a single large exemption before tax applies, while inheritance tax systems typically provide relationship-based allowances with progressive rates.

UK Inheritance Tax is charged at 40% on the value of an estate above the nil-rate band (NRB) of £325,000. This threshold has been frozen since 2009 and remains at £325,000 for 2026/27. The residence nil-rate band (RNRB) provides an additional £175,000 when a main residence is passed to direct descendants (children, grandchildren, step-children, and adopted children).

For married couples and civil partners, any unused NRB and RNRB can be transferred to the surviving spouse, effectively doubling the thresholds. A couple can therefore pass up to £1 million to their children tax-free (£325,000 + £175,000 × 2). The RNRB tapers by £1 for every £2 that the estate exceeds £2 million, meaning estates above £2.35 million lose the RNRB entirely.

Charitable giving reduces the IHT rate. If 10% or more of the net estate is left to charity, the tax rate on the remaining taxable estate reduces from 40% to 36%. Business Relief (BR) and Agricultural Relief (AR) can provide 50% or 100% relief on qualifying business and farm assets. Potentially Exempt Transfers (PETs) allow lifetime gifts to become tax-free if the donor survives seven years.

The United States imposes a federal estate tax on estates exceeding the lifetime exemption, which is $13.99 million per individual for 2026 (adjusted from $13.61 million in 2025). This exemption is portable between spouses, allowing a married couple to shield approximately $27.98 million from federal estate tax. Tax rates on the taxable estate are progressive, ranging from 18% on the first $10,000 above the exemption to 40% on amounts exceeding $1 million above the exemption.

A critical uncertainty for 2026 is the sunset of the Tax Cuts and Jobs Act (TCJA) provisions. Unless Congress extends them, the estate tax exemption will revert to the 2017 level adjusted for inflation — approximately $7 million per person — beginning 1 January 2026. This would more than double the number of estates subject to federal estate tax.

In addition to federal tax, twelve states and the District of Columbia impose their own estate taxes, and six states impose inheritance taxes (Iowa, Kentucky, Maryland, Nebraska, New Jersey, Pennsylvania). Maryland is the only state with both. State exemptions are typically much lower than the federal exemption — for example, Oregon and Massachusetts exempt only $1 million, while New York matches the federal exemption but has a "cliff" that eliminates the exemption for estates exceeding 105% of the threshold.

Ireland taxes gifts and inheritances under Capital Acquisitions Tax (CAT) at a flat rate of 33%. The tax-free threshold depends on the relationship between the disponer (person giving) and the beneficiary (person receiving), and these thresholds are lifetime aggregates. For 2026, Group A (parent to child, including adopted and step-children) has a threshold of €335,000. Group B (lineal ancestor/descendant, sibling, niece/nephew) has €32,500. Group C (all other relationships, including unmarried partners) has €16,250.

The dwelling house exemption allows a beneficiary to inherit a residential property completely tax-free if they have lived in it for three years prior to inheritance and continue to occupy it for six years after (with exceptions). Business Relief provides 90% relief on qualifying business assets, meaning CAT is effectively 3.3% on business property. Agricultural Relief similarly provides 90% relief on qualifying farm property. The small gift exemption allows tax-free gifts of up to €3,000 per year from any one disponer to any one beneficiary.

French succession tax applies to worldwide assets of French residents and French situs assets of non-residents. Transfers between spouses and PACS partners are completely exempt. Children benefit from a €100,000 allowance each (€159,325 if the parent is under 70 at the time of gift). Grandchildren receive a €31,865 allowance. Siblings receive a €15,932 allowance.

Tax rates are progressive from 5% to 45% for direct line descendants. The top 45% rate applies to portions exceeding €1,805,677 per child. For siblings, rates range from 35% to 45%. For unrelated beneficiaries, the flat rate is 60% with a €1,594 allowance. The family home can benefit from a 30% reduction in value if occupied by the surviving spouse or dependent children.

German inheritance tax provides generous personal allowances based on relationship. Spouses receive €500,000 plus a pension allowance (up to €256,000 depending on age). Children and step-children receive €400,000. Grandchildren receive €200,000. Parents and grandparents receive €100,000. Siblings, nieces, and nephews receive €20,000. All others receive €20,000.

Tax rates are progressive within three tax classes. Tax Class I (spouse, children, parents in some cases) has rates from 7% to 30%. Tax Class II (siblings, nieces, nephews, step-parents) has rates from 15% to 43%. Tax Class III (unrelated persons) has rates from 30% to 50%. Business property can qualify for up to 85% relief (full exemption for up to €150,000, then 85% relief on the remainder) if employment levels are maintained for 5-7 years.

Spanish inheritance tax is among the most complex in Europe because each of Spain's 17 autonomous communities sets its own allowances, reductions, and tax rates in addition to the state-level framework. The state tax scale ranges from 7.65% to 34% for inheritances up to €797,555, with a flat 36.5% above that. However, regional modifications can dramatically alter the effective tax.

Madrid completely abolished inheritance tax for spouses, descendants, and ascendants in 2016. Andalucía offers a €1 million allowance for close family. Catalonia has its own progressive scale with significant allowances for spouses (€100,000) and children (€275,000 for under-21s). Valencia and the Balearic Islands also offer substantial reductions. Non-residents inheriting Spanish property are subject to the state rules unless a double tax treaty provides relief.

Italy has one of the most favorable inheritance tax regimes in the EU. Transfers to spouses, children, and grandchildren are completely exempt up to €1 million per beneficiary. Transfers to siblings are exempt up to €100,000 each. Other relatives up to the fourth degree receive a €100,000 exemption. Above these thresholds, the tax rate is only 4% for close family, 6% for siblings and other relatives, and 8% for unrelated persons.

The main family home (prima casa) transferred to a spouse or children is completely exempt from inheritance tax regardless of value, provided the beneficiary already lives there or intends to make it their main residence. This makes Italy particularly attractive for family wealth preservation. Business property can also benefit from significant reliefs under the "Bersani decree" provisions.

Canada does not have a formal inheritance tax or estate tax. Instead, the Income Tax Act deems a person to have disposed of all capital property immediately before death at fair market value. This triggers capital gains tax on the appreciation of assets such as real estate (other than a principal residence), stocks, bonds, and business interests. The top combined federal/provincial capital gains inclusion rate is approximately 27% in high-tax provinces like Nova Scotia and Ontario.

Transfers to a surviving spouse or common-law partner can be deferred through a spousal rollover, meaning no tax is due until the surviving spouse disposes of the assets or dies. Registered Retirement Savings Plans (RRSPs) and Registered Retirement Income Funds (RRIFs) are fully taxable as income in the year of death unless rolled over to a spouse or financially dependent child. Probate fees (estate administration tax) vary by province, from minimal amounts in Quebec to 1.5% of estate value in Ontario above $50,000.

Australia abolished federal inheritance taxes in 1979, and no state currently imposes a death duty. However, Capital Gains Tax (CGT) may apply when beneficiaries dispose of inherited assets. The general rule is that the beneficiary acquires the asset at the deceased's cost base (original purchase price), and CGT is payable on any gain from that point when the beneficiary eventually sells.

A principal residence inherited from a deceased is generally exempt from CGT if sold within two years of death. Assets acquired by the deceased before 20 September 1985 are exempt from CGT entirely. Superannuation death benefits paid to dependent beneficiaries are tax-free, while non-dependents may pay tax at 15% plus Medicare levy on the taxable component.

India abolished estate duty in 1985 and has not reintroduced it. There is currently no inheritance tax, estate tax, or succession duty at the national level. However, transferring immovable property through inheritance requires payment of stamp duty (typically 3-8% depending on the state) and registration fees. Some states like Maharashtra charge 1% stamp duty on the market value of inherited property.

Inherited property is not subject to income tax at the time of inheritance. However, if the beneficiary later sells the property, capital gains tax applies. The holding period for calculating long-term capital gains includes the period the deceased held the property. The cost basis is stepped up to the fair market value as of the date of inheritance.