Full Definition
Estate tax is charged on the total estate before distribution (US: 40% above $13.6M federal exemption). Inheritance tax is charged per beneficiary (UK: 40% above £325,000; France: 5–45% with family exemptions). Many countries have none: Portugal, Sweden, Austria, Canada, Australia, Singapore, UAE. For cross-border estates, double taxation can occur if assets span multiple jurisdictions.
Global Rates at a Glance
France
30%
Capital Gains Tax
Germany
26.4%
Capital Gains Tax
United States
20%
Capital Gains Tax
United Kingdom
24%
Capital Gains Tax
Singapore
0%
Capital Gains Tax
Portugal
28%
Capital Gains Tax
Switzerland
0%
Capital Gains Tax
Key Facts for Expats & Digital Nomads
CGT planning is most impactful for those selling businesses or significant equity. Establishing residency in a zero-CGT jurisdiction (UAE, Singapore, New Zealand) before a major exit can be highly valuable — but requires genuine relocation well in advance. Exit tax rules mean you may need to crystallise gains before departing Germany, the US, or France.
Frequently Asked Questions
What is Inheritance & Estate Tax?
Tax levied on the transfer of assets at death — charged either to the estate or to the beneficiary. Estate tax is charged on the total estate before distribution (US: 40% above $13.6M federal exemption). Inheritance tax is charged per beneficiary (UK: 40% above £325,000; France: 5–45% with family exemptions). Many countries have none: Portugal, Sweden, Austria, Canada, Australia, Singapore, UAE. F.
Which countries have the lowest Inheritance & Estate Tax?
Zero CGT countries: UAE, Singapore, New Zealand (most assets), Switzerland (most assets), Belgium (most assets), Hong Kong, Cayman Islands. Mid-range: UK 10–20%, US 0–20% long-term. France applies a flat 30% (PFU).
How does Inheritance & Estate Tax affect expats and digital nomads?
CGT planning is most impactful for those selling businesses or significant equity. Establishing residency in a zero-CGT jurisdiction (UAE, Singapore, New Zealand) before a major exit can be highly valuable — but requires genuine relocation well in advance. Exit tax rules mean you may need to crystallise gains before departing Germany, the US, or France.
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Disclaimer: This information is for educational purposes only and does not constitute tax advice. Tax laws change frequently. Consult a qualified tax professional before making any decisions.