Inheritance tax on property abroad: twenty-three countries, side by side.
// Short answer
Of the twenty-three countries we have checked against their own laws, Cyprus, Malaysia, Panama and Costa Rica charge no inheritance tax at all, and in Portugal, Croatia, Montenegro, Vietnam and Cambodia close family pay nothing on inherited property. Thailand taxes only inheritances above THB 100 million per heir. At the other end, Japan's rates run to 55%, Germany's to 50% for heirs outside the family, and France's to 45% for children.
Rules and rates as of October 2026, as published on each country page. Not legal or tax advice.
On this page
Which countries charge no inheritance tax on property?
Cyprus (abolished for deaths from 1 January 2000), Malaysia (estate duty abolished in 1991), Panama (abolished in 1985) and Costa Rica. Portugal, Croatia, Montenegro, Vietnam and Cambodia tax inherited property only when the heir is not close family, and Thailand only above THB 100 million per heir.
| Country | Tax on a non-resident heir | Reserved share for children | Deadline |
|---|---|---|---|
| Cyprus | None (abolished for deaths from 1 January 2000) | Yes: with children, only a quarter is free | Estate statement to the Tax Commissioner within 6 months |
| Malaysia | None (estate duty abolished 1991) | No fixed share for non-Muslims | A grant within 6 months, or the court may appoint Amanah Raya |
| Portugal | None for spouse, children or parents; 10% stamp duty for other heirs | Yes: up to two-thirds reserved | Report the death by the end of the 3rd month after it |
| Italy | 4% above EUR 1,000,000 per child or spouse (2026 rules) | Yes: a half to two-thirds for children | 12 months |
| Greece | First EUR 150,000 free, then 1% to 10% for close family | Yes: half of the intestate share | 9 months, or 1 year if death or heirs abroad |
| Philippines | 6% of the net estate, after a PHP 500,000 deduction for a non-resident foreigner | Follows the deceased's national law | 1 year |
| France | EUR 100,000 free per child per parent, then 5% to 45%; spouse exempt | Yes: a half to three-quarters for children | 6 months (death in France) or 12 months |
| Spain | State scale 7.65% to 34%, times 1.0 to 2.4; regional rules can apply to non-residents | Yes: two-thirds for descendants | 6 months, extendable by 6 |
| Japan | JPY 30M + 6M per heir deducted, then 10% to 55% | Follows the deceased's national law | 10 months |
| Thailand | Only above THB 100M per heir: 10% (5% for parents and children) | Not covered here | 150 days; a non-qualifying foreign heir must sell a condo within 1 year |
| Germany | EUR 400,000 free per child, EUR 500,000 spouse, then 7% to 50% | Yes: half the statutory share, as a money claim | Notify the tax office within 3 months |
| Turkey | TRY 2,907,136 free per child or spouse (2026), then 1% to 10% | Yes: half for descendants | 4 to 8 months by where heirs live |
| Dubai | None found in any official source; AED 1,000 title transfer | None for a non-Muslim with a registered will | 60 days to accept a bequest |
| Vietnam | Close family exempt; others 10% above VND 20M | Yes: two-thirds of the intestate share | Not covered here |
| Bali | BPHTB up to 5% (allowance of IDR 300M+ for close family); no income tax | Not covered here | A foreign heir must give up Hak Milik within 1 year |
| Cambodia | 4% stamp duty; close family exempt | Not covered here | Not covered here |
| Croatia | 3% transfer tax; close family exempt | Yes: half for children and spouse | 15 days after the assessment |
| Montenegro | 3% to 6% transfer tax; children, spouse, parents exempt | Yes: half for children and spouse | 15 days |
| Colombia | 15% occasional-gains tax after UVT exemptions | Yes: half the estate | Not covered here |
| Mexico | No federal inheritance tax; a non-resident heir should check Income Tax Law art. 160 | No forced share | Not covered here |
| Costa Rica | None; the heir's adjudication usually pays the 1.5% transfer tax | No fixed share; maintenance for dependants | Not covered here |
| Panama | None (abolished 1985) | No forced heirs; maintenance for dependants | Not covered here |
| Dominican Republic | 3% of the net estate; exempt under RD$1M (RD$2M direct-line heirs) | Yes: half to three-quarters for children | 90 days |
Each country name opens the full page, with the law and the official source for every figure.
Sources
Where is inheritance tax on property highest?
By top rate: Japan (55% on the largest shares, after a deduction of JPY 30 million plus 6 million per heir), Germany (50% for heirs outside the family, 30% for children), France (45% for children above EUR 1,805,677) and Spain (34% on the state scale, multiplied by up to 2.4 for distant heirs).
Top rates mislead on their own. A French child has EUR 100,000 free per parent; an Italian child pays nothing below EUR 1,000,000; a Greek child nothing below EUR 150,000. What matters is the size of the share and the relationship. Spain's regional rules, which non-residents can now use, often change the result more than the state scale does.
Sources
Which country's law decides who inherits property abroad?
In the six EU countries here, the EU Succession Regulation applies: by default the law of the country where the owner lived at death, unless the will chooses the law of their nationality. Japan and the Philippines apply the deceased's national law. Malaysia shares the land of a non-Muslim who dies without a will under its own Distribution Act, wherever they lived.
That is why a British or American owner of property in Spain, France or Italy should know whether their will makes the choice of national law. Without it, the forced shares in the table can apply to the property. Tax is a separate question: the country where the property is taxes it under its own rules either way.
Sources
How long does probate take abroad?
None of the twenty-three publishes an official typical length. What each does fix is a deadline: from three months (Portugal, to report the death) to a year (the Philippines, for the estate tax return), and in Japan, three years to register the inherited property.
The deadlines in the table are the dates penalties start, not how long it takes. A court process (the Philippines, Cyprus, Malaysia) usually adds time compared with a notary process (Spain, France, Italy, Greece, Portugal), but no official body publishes those durations.
Sources
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