Inheritance tax in Europe – country comparison
Inheritance tax rules in Europe are famously uneven: one country abolished the tax entirely, its neighbour taxes at up to 65%. If you inherit across borders – common for expats, cross-border workers and second-home owners – the differences matter. This guide summarises the rules of the eight German-, French-, Italian- and Dutch-speaking countries.
Switzerland
Levied by the cantons, not the federal state. Spouses and (in most cantons) direct descendants are fully exempt. Rates for unrelated heirs range from 15% to about 50% depending on the canton. Schwyz and Obwalden have no inheritance tax at all; Zurich and Bern have moderate rates. Deadline to file: usually 3 to 6 months after death.
Germany
Federal tax. Three tax classes based on relationship: class I (spouse, children) has an allowance of €500,000 for spouses and €400,000 per child, with rates from 7% to 30%. Class II (siblings, nieces, in-laws) starts at 15%, class III (unrelated) at 30% and up to 50% for large estates. Return due within 3 months of learning of the death.
Austria
Inheritance tax was abolished in 2008. However, transfers of real estate still trigger the property acquisition tax (Grunderwerbsteuer) at 0.5% to 3.5% of the tax value. Reporting deadline: within one month at the tax office (FinanzOnline).
Liechtenstein and Luxembourg
Liechtenstein has no inheritance tax, only registration fees. Luxembourg has a modest tax: direct descendants and spouses are largely exempt, siblings and unrelated heirs pay progressive rates up to 48% on very large estates. Return due 6 months after death.
Belgium
Levied by the regions (Flanders, Brussels, Wallonia). Direct line rates in Flanders: 3% up to €50,000, 9% up to €250,000, 27% above. Rates for unrelated heirs reach 55%. Family home is fully exempt for the surviving spouse or cohabiting partner in Flanders. Return due within 4 months of a death in Belgium.
France
National tax. Spouses and civil partners (PACS) are fully exempt. Children have a €100,000 allowance per parent, with rates from 5% to 45%. Siblings pay 35% to 45%; unrelated heirs pay a flat 60%. Return due within 6 months of a death in France, 12 months if abroad.
Italy
Among the lowest rates in Europe. Spouses and direct descendants: 4% above a €1,000,000 allowance per beneficiary. Siblings: 6% above €100,000. Other relatives: 6% with no allowance. Unrelated heirs: 8% with no allowance. Return due within 12 months. Property transfers also incur cadastral and mortgage taxes of 2%–3%.
Cross-border inheritance and planning
The EU Succession Regulation (Brussels IV) allows an EU resident to choose the law of their nationality to govern their estate – vital for expats. Double-taxation treaties are rare in inheritance tax, so heirs may pay in two countries; France, Germany and Austria have bilateral treaties covering specific cases. Speak to a notary early. The Wegbegleiter app (wegbegleiterapp.com) bundles country pages and a downloadable comparison table. Explore them at wegbegleiterapp.com.
Frequently asked questions
- Which European country has no inheritance tax?
- Austria and Liechtenstein have no inheritance tax; several Swiss cantons also exempt direct descendants.
- How is a cross-border inheritance taxed?
- Usually by the country where the deceased was habitually resident, plus the country where any real estate is located.
- Can I choose which law applies to my estate?
- Yes – under Brussels IV, an EU resident may elect the law of their nationality by will.
- When do I have to file?
- From 3 months (Germany) to 12 months (Italy, France if abroad). Check the country page.
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