Estate, inheritance and gift taxes vary widely across Europe. As of 2024, 35 EU member states and European OECD countries either levy a tax on estates, inheritances, gifts, or apply no such tax, with rates ranging from 0 % to 87.6 % depending on the jurisdiction and the value transferred.
Tax presence by country
| Country | Tax on estate/inheritance/gift? | Rate range* |
|---|---|---|
| Austria | No | – |
| Belgium | Yes | 3 % – 80 % |
| Bulgaria | Yes | 0.4 % – 6.6 % |
| Croatia | Yes | 4 % |
| Cyprus | No | – |
| Czech Republic | Yes* | Income‑tax rates (inheritances exempt, gifts taxed as personal income) |
| Denmark | Yes | 0 % – 52.07 % |
| Estonia | No | – |
| Finland | Yes | 7 % – 33 % |
| France | Yes | 5 % – 60 % |
| Georgia | No | – |
| Germany | Yes | 7 % – 50 % |
| Greece | Yes | 1 % – 40 % |
| Hungary | Yes | 9 % – 18 % |
| Iceland | Yes | 10 % (inheritance); gifts taxed as personal income |
| Ireland | Yes | 33 % |
| Italy | Yes | 4 % – 8 % |
| Latvia | No | – (gifts may trigger income tax) |
| Lithuania | Yes | 5 % – 10 % |
| Luxembourg | Yes | 0 % – 48 % |
| Malta | No | – (capital‑gains and property transfer taxes may apply) |
| Moldova | No | – |
| Netherlands | Yes | 10 % – 40 % |
| Norway | No | – |
| Poland | Yes | 0 % – 20 % |
| Portugal | Yes | 10 % |
| Romania | No | – (real‑estate transfers may be taxed) |
| Slovakia | No | – |
| Slovenia | Yes | 5 % – 39 % |
| Spain | Yes | 7.65 % – 87.6 % |
| Sweden | No | – (capital‑gains tax may apply) |
| Switzerland | Yes | 0 % – 50 % (canton‑dependent) |
| Turkey | Yes | 1 % – 30 % |
| Ukraine | Yes | Personal income‑tax rate applies |
| United Kingdom | Yes | 20 % – 40 % |
*Rates shown are the statutory maximums; actual liability depends on relationship to the deceased, asset type, and thresholds.
Key observations
- No estate/inheritance/gift tax: Austria, Cyprus, Estonia, Georgia, Latvia, Malta, Moldova, Norway, Romania, Slovakia, Sweden. Some of these jurisdictions still tax gifts or capital gains under separate regimes.
- High‑rate jurisdictions: Spain (up to 87.6 %), Belgium (up to 80 %), France (up to 60 %), Switzerland (up to 50 % depending on canton).
- Flat or low rates: Croatia (4 %), Italy (4 %–8 %), Portugal (10 %), Poland (0 %–20 %).
- Income‑tax linkage: Czech Republic treats gifts as ordinary income; Iceland taxes gifts via personal income tax; Ukraine applies the personal income‑tax rate to inheritances and gifts.
Practical considerations for cross‑border planning
- Residency vs. situs: Many countries tax based on the decedent’s tax residency, while others tax assets located within their borders. Verify both residence and asset location rules.
- Treaty relief: Double‑taxation agreements may mitigate overlapping liabilities, especially between EU members.
- Thresholds and exemptions: Several jurisdictions (e.g., Denmark, Poland) have zero‑rate bands or exemptions for close relatives; the effective rate can be substantially lower than the statutory maximum.
- Canton variation in Switzerland: Tax rates differ markedly between cantons; local advice is essential.
- Gift vs. inheritance timing: In countries where gifts are taxed as income (Czech Republic, Iceland, Ukraine), transferring assets during life may trigger higher tax than waiting for inheritance, depending on the recipient’s tax bracket.
Sources
- EY, Worldwide Estate and Inheritance Tax Guide 2024 (2024)
- PwC, Worldwide Tax Summaries (accessed 3 Apr 2025)
- Bloomberg Tax, Country Guides (accessed 3 Apr 2025)
Data compiled by Cristina Enache, Tax Foundation.
Source article: taxfoundation.org
