Inheritance tax rates across Europe – how does Britain compare to other countries? (2024)

Households in Britons are being hit with a 40 per cent tax charge but do our neighbours in Europe have to pay the same?

Inheritance tax receipts in the UK has soared in recent months due to fiscal drag with our countries in the continent having similar tax charges on their populace.

What is inheritance tax?

This is levy imposed by many Governments on the estates, including their money, possessions and property, of their citizens after they passed away.

The unpopular tax is charged when an estate is moved from a deceased individual to any number of beneficiaries.

Usually, spouses or civil partners are not liable to pay IHT, however other beneficiaries could have to pay the charge.

These include direct descendants, such as children or grandchildren, parents, siblings, friends and business partners.

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Inheritance tax rates across Europe – how does Britain compare to other countries? (1)

Some households are being hit with a sizable tax charge after their loved ones die

GETTY

How much inheritance tax do Britons pay?

As it stands, inheritance tax is paid at a 40 per cent rate to HM Revenue and Customs (HMRC) if the estate is above the £325,000 threshold.

It is due within six months after the estate owner’s death, at which point interest will accrue based on the Bank of England’s base, if has not been paid.

IHT is paid directly to HMRC by the executor of the will, or legal representative involved in handling the estate.

The tax due is paid to the Government department through a direct transfer of funds or by selling off property equity.

How much do other countries in Europe pay in inheritance tax?

  • Austria – No inheritance tax paid
  • Belgium – Yes, inheritance tax paid at rate of between three to 80 per cent depending on region.
  • Bulgaria – Yes, inheritance tax paid at rate of between 0.4 to 6.6 per cent
  • Croatia – Yes, inheritance tax paid at rate of four per cent
  • Cyprus – No inheritance tax paid
  • Czechia – Yes, income tax applies with inheritances being fully tax-exempt but gifts may be taxed
  • Denmark – Yes, inheritance tax paid at rate of zero to 52 per cent
  • Estonia – No inheritance tax paid
  • Finland – Yes, inheritance tax paid at rate of between seven to 33 per cent
  • France – Yes, inheritance tax paid at rate of between five to 60 per cent
  • Germany – Yes, inheritance tax paid at rate of between seven to 50 per cent
  • Greece – Yes, inheritance tax paid at rate of between one to 40 per cent
  • Hungary – Yes, inheritance tax paid at rate of between ine to 18 per cent
  • Iceland – Yes, inheritance tax paid at rate of 10 per cent
  • Ireland – Yes, inheritance tax paid at rate of 33 per cent
  • Italy – Yes, inheritance tax paid at rate of between four to eight per cent.
  • Latvia – No inheritance tax paid on estates income applies to gifts.
  • Lithuania – Yes, inheritance tax paid at rate of between five to 10 per cent
  • Luxembourg – Yes, inheritance tax paid at zero to 48 per cent
  • Malta – No inheritance tax paid but five perc cent transfer duty can apply.
  • Netherlands – Yes, inheritance tax paid at rate of between 10 40 per cent.
  • Norway – No inheritance tax paid
  • Poland – Yes, inheritance tax paid at rate of between zero to 20 per cent
  • Portugal – Yes, inheritance tax paid at rate of 10 per cent
  • Romania – No inheritance tax paid except in relation to transfer retail estate in certain situations
  • Slovakia – No inheritance tax paid
  • Slovenia – Yes, inheritance tax paid at rate of between five to 39 per cent.
  • Spain – Yes, inheritance tax paid at rate of 7.65 to 87.6 per cent depending on the region
  • Sweden – No inheritance tax paid.
  • Switzerland – Yes, inheritance tax paid at rate of between zero to 50 per cent depending on caton
  • Turkey – Yes, inheritance tax paid at rate of between one to 30 per cent
  • UK – Yes, inheritance tax paid at rate of between 20 to 40 per cent.

Since 2022, there was no inheritance, estate and gift taxes in eight European Union countries, the Tax Foundation found.

These include Austria, Cyprus, Estonia, Latvia, Malta, Romania, Slovakia and Sweden. Among the EFTA countries, there were also no wealth transfer taxes in Norway.

Laura Hayward, the tax partner Evelyn Partners, noted that the UK has seen a hike in IHT receipts due to fiscal drag.

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Inheritance tax rates across Europe – how does Britain compare to other countries? (2)

In the UK, fiscal drag has led to inheritance tax receipts rising

GETTY

This happens when tax thresholds, such as the £325,000 inheritance tax amount, remain frozen while the cost of estates go up.

She explained: “IHT is harvesting more in revenue than was ever forecast as rising house prices and growth in investment assets have boosted the value of estates over the last couple of decades.

“This has drawn more estates, and more assets in each liable estate, over the threshold at which IHT kicks in, which has been frozen at £325,000 since April 2009. Modest property downturns as we have seen in the last year or so will do little to dent this trend.

“In recent years there has also been a Covid effect on mortality which has further increased the overall IHT take.”

Inheritance tax rates across Europe – how does Britain compare to other countries? (2024)

FAQs

Inheritance tax rates across Europe – how does Britain compare to other countries? ›

Netherlands – Yes, inheritance tax paid at rate of between 10 40 per cent. Slovenia – Yes, inheritance tax paid at rate of between five to 39 per cent. Sweden – No inheritance tax paid. UK – Yes, inheritance tax paid at rate of between 20 to 40 per cent.

How does UK inheritance tax compare internationally? ›

Ireland would typically take 26%, and the UK 25.8% from the estate of an individual passing on an estate worth US$3m* to their heirs, well above the global average of 7.67%. For UK individuals that have never been married, the amount of inheritance tax taken from their estate would be even higher at 32.9%.

Which European country has the highest inheritance tax? ›

In 2022, the maximum inheritance tax rate ranged from 4% in Croatia to 88% in Spain, depending on the region. Most European countries also implement inheritance and estate tax exemption thresholds.

How does UK tax compare to Europe? ›

The United Kingdom ranked 16th¹ out of 38 OECD countries in terms of the tax-to-GDP ratio in 2022. In 2022, the United Kingdom had a tax-to-GDP ratio of 35.3% compared with the OECD average of 34.0%. In 2021, the United Kingdom was ranked 21st out of the 38 OECD countries in terms of the tax-to-GDP ratio. 1.

What is the inheritance tax in the UK vs Ireland? ›

The treaty between Ireland and the United Kingdom (UK) covers CAT in Ireland and Inheritance Tax in the UK. Ireland charges CAT based on the residence of the deceased person (the disponer) or the person who receives the benefit (the beneficiary). The UK charges tax based on the domicile of the deceased person.

Are UK taxes higher than US? ›

The basic rate of tax in the UK is 20%, which applies to income above the personal allowance and up to a higher threshold. The UK has a higher rate of tax of 40% and an additional rate of tax of 45% for the highest earners.

What is the most taxed country in Europe? ›

Denmark is the European country with the highest top statutory income tax rate as of 2024, with the Nordic country having a top taxation band of 55.9 percent.

What is the inheritance tax in Germany? ›

German inheritance tax rate ranges from 7% to 50%, depending on the: (1) degree of kinship between the heir and decedent, and (2) size of the inheritance share.

What is the inheritance tax in France? ›

Inheritance Tax in France

If you have one child – 50% If you have two children – 66% If you have three or more children – 75%

What is the inheritance tax in Switzerland? ›

First CHF 250'000 inheritance is exempt and the tax rate on the excess varies between 0.1% and up to 7% over an amunt of CHF 1.300 million; First CHF 50'000 gift per year is exempt and the tax rate on the excess varies between 0.1% and up to 7% over an amount of CHF 1.302 million.

Are French taxes higher than the UK? ›

The UK one-earner married couple with two children pays 70% more income tax than the French family, more than twice as much as the US family, and 15 times as much as the German family. By contrast, the UK income tax burden on a single person without children is 14% less than the OECD average at the OECD average wage.

Does Germany have higher taxes than UK? ›

Indeed, the average tax rate. Read more of top earners in the UK was higher than in a number of countries that had a higher tax burden overall, such as Germany and Italy. SSCs in all countries tend to be less progressive.

Are taxes higher in Spain than the UK? ›

Income Tax: Spain uses a progressive income tax system similar to the UK, ranging from 19% to 47%. The UK rates are between 20% and 45%. The highest tax rate applies to a lower income level in Spain than in the UK, so higher earners might pay more income tax in Spain.

What is the 7 year rule in inheritance tax in Ireland? ›

If the donor dies within the 7 years from the date of the gift/transfer and the gift(s) are worth more than the IHT Nil Rate Band at the date of their death, a taper relief method will apply to same. How much tax is due depends on the value of the gift, when it was given and to whom.

How much can you inherit in Ireland without paying inheritance tax? ›

Avoiding inheritance tax in Ireland
DaughterSon
Total Inheritance€950,000€950,000
Child Free Threshold€335,000€335,000
Grandchild Tax-Free Threshold€65,000€97,500
Great Grandchild Tax-Free Threshold€32,500
5 more rows
Apr 18, 2024

Do the rich pay inheritance tax UK? ›

The super-rich and inheritance tax

This is despite the fact that only 5% of estates each year are actually affected by IHT. From the 2021/2022 tax year, it is possible for a married couple, or couple in a civil partnership, to pass on up to £1 million in inheritance without paying inheritance tax.

Do I pay UK inheritance tax on overseas inheritance? ›

When someone living outside the UK dies. If your permanent home ('domicile') is abroad, Inheritance Tax is only paid on your UK assets, for example property or bank accounts you have in the UK. It's not paid on 'excluded assets' like: foreign currency accounts with a bank or the Post Office.

Will I be taxed if I receive inheritance money from overseas? ›

No, the IRS does not impose taxes on foreign inheritance or gifts if the recipient is a U.S. citizen or resident alien. However, you may need to pay taxes on your inheritance depending on your state's tax laws.

What is the inheritance tax in the US and UK? ›

Tax rates are not dissimilar in the US and UK. The US federal estate tax applies progressive tax rates, but the highest US estate tax rate matches the UK inheritance tax rate of 40%.

Are UK citizens taxed on worldwide income? ›

Generally, the UK tax system taxes anyone who is resident in the UK on their worldwide income and gains. On the other hand, if you are non-resident in the UK, your foreign income and gains are not in scope of UK tax.

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