Estate and Inheritance Tax for Global Investors: A Map of the Major Regimes
Inheritance and estate tax catches more cross-border investors than they expect. A practical comparison of the major regimes and how to plan around them.
The range is enormous — and surprising
Estate and inheritance tax rates range from 0% (Australia, New Zealand, Canada, Sweden, Norway, Israel, UAE, Singapore) to 40–55% in the US (above the exclusion), UK, Japan, France and Germany. The jurisdiction that applies depends on the deceased's residency, the heir's residency, and where the assets sit.
US-situs assets (US-listed shares, US real estate, US-domiciled funds) can trigger US estate tax for non-US persons on amounts above just $60,000 — a trap many non-US investors are completely unaware of.
Why structure matters more than will-drafting
A will distributes what you own. It does not change what tax applies. Assets held personally in a high-tax jurisdiction are exposed regardless of who inherits them. Assets held through a corporate structure, trust or foundation may sit outside the inheritance tax base entirely.
Sophisticated planning therefore happens before death, through holding-structure design — not after, through will drafting.
Common traps for cross-border investors
Holding US-listed ETFs personally as a non-US resident. Owning second homes in France, Spain or Italy without forced-heirship planning. Mixing residency between jurisdictions with different inheritance regimes during the years before death. Naming heirs in jurisdictions that tax incoming inheritance.
Every Aqmār investor with cross-border exposure should map their estate exposure at least once, and revisit it on every major life change.
Ready to invest with structure?
Browse vetted projects on Aqmār — every deal held in escrow until ownership and documentation are verified.