Countries with No Inheritance Tax [2026]: Moving Abroad and Japan's 10-Year Rule

Countries and territories with no inheritance tax or estate tax include Australia, New Zealand, Singapore, Hong Kong, Malaysia, the UAE (Dubai), Sweden and Norway — 25 in total among those checked for this article (some, such as Canada, have no inheritance tax but levy income tax on death). However, simply moving to a country without inheritance tax does not reduce Japanese inheritance tax. Where both parent and child are Japanese nationals, foreign assets fall outside Japanese inheritance tax only if both the deceased (the decedent) and the person receiving the assets (the heir) have had no domicile in Japan during the 10 years before the death. This test is applied to each heir separately. In addition, real estate in Japan, deposits with banks in Japan and shares in Japanese companies remain subject to Japanese inheritance tax no matter how many years you have lived abroad. Japanese inheritance and gift tax is based mainly on where people live, not only on nationality, so it can also apply to foreign nationals living in Japan and to their heirs; the rules for foreign nationals are explained in a separate section below. Based on public information from the National Tax Agency, e-Gov (Japanese laws database), tax authorities of each country and PwC's country tax summaries, this article covers the following.

*Amounts and rules are as of October 15, 2026. This article is an English version of our Japanese guide, adapted for foreign residents of Japan and international investors.

• Main countries with no inheritance or estate tax, and the taxes they levy instead (deemed disposal, stamp duty, etc.)
• Main countries that do have inheritance or estate tax (the US, the UK, Thailand, the Philippines, Europe, South Korea and Taiwan)
• The "both decedent and heir for 10 years" condition for removing foreign assets from Japanese inheritance tax, with cases by family living arrangement
• Pitfalls: acquiring a foreign nationality, Japan's exit tax, assets in Japan and double taxation

*This article is a general explanation based on public information as of October 15, 2026 (National Tax Agency, e-Gov, the US Internal Revenue Service (IRS), the UK government, tax authorities of each country, PwC Worldwide Tax Summaries, etc.). Tax systems change, and whether inheritance tax is payable and how much depends on individual circumstances. For filing and payment decisions, please consult the tax office or a licensed tax accountant.

Conclusion: living in a no-inheritance-tax country does not by itself reduce Japanese inheritance tax

Under Japan's Inheritance Tax Act (Articles 1-3 and 2), who is liable for Japanese inheritance tax and which assets are taxed are determined regardless of whether your destination country has an inheritance tax. For Japanese nationals who move abroad, the conclusion comes down to three points.

"Having a domicile in Japan" does not mean having a resident registration; it means that the center of your life is in Japan. This is judged not only by the number of days spent in Japan but also by where your family lives, where you work, where your assets are and so on. The National Tax Agency explains that people who are temporarily away from Japan, for example for study or a business trip, are treated as having a domicile in Japan. In the Takefuji case (Supreme Court judgment of February 18, 2011), in which domicile was disputed, Japanese gift tax was cancelled because the center of the recipient's life was found to be in Hong Kong at the time of the gift. The 10-year rule was introduced after this case, and today moving your domicile abroad is no longer enough.

In other words, moving to a country without inheritance tax can only narrow the scope of Japanese inheritance tax where the family moves abroad together, keeps living there for more than 10 years and holds most of its assets outside Japan. If the destination is a country that levies inheritance or estate tax, such as the US or the UK, inheritance tax will be charged there even if Japanese tax no longer applies. The resident registration, income tax and local inhabitant tax procedures needed before and after leaving Japan are covered in Taxes and resident registration when moving abroad. For a country-by-country comparison including income tax and corporate tax, see Countries with the lowest taxes.

Main countries with no inheritance or estate tax

An estate tax is levied on the whole estate of the deceased (as in the US and the UK), while an inheritance tax is levied on the assets received by each heir (as in Japan). The countries and territories below have neither. The right-hand column shows the month in which the PwC Worldwide Tax Summaries page for each country was last reviewed (checked for this article on October 15, 2026). New Zealand, Cyprus and Estonia were confirmed using PwC's summary table and materials from the relevant authorities.

In addition, the official website of Dominica's citizenship program states that there is "no inheritance or gift tax", and the website of Vanuatu's government investment promotion agency states that there are "no death duties". Both statements come from program information pages and could not be confirmed in tax authority materials. For Nauru, the taxes published by the Nauru Revenue Office (employment and services tax, business tax, etc.) do not include an inheritance or gift tax. Monaco does not charge inheritance tax to a spouse or lineal relatives but does charge it to other relatives and others, so it is not included in the table. If you want to compare destination countries one by one, see also Best countries to move abroad.

Countries with "no inheritance tax" that still levy other taxes

Even in countries described as having "no inheritance tax", an inheritance may trigger a tax under a different name, such as income tax, stamp duty or real estate acquisition tax.

UAE: no tax, but watch the rules on dividing the estate

The UAE has no inheritance tax, but you need to pay attention to the rules on how the estate is divided. Inheritances of Muslims are handled under Islamic law (Sharia). For non-Muslim foreign nationals, Federal Decree-Law No. 41 of 2022, which took effect in 2023, applies in principle, and where there is no will the estate is distributed without distinction between men and women. If you make a will, you can register it under the DIFC (Dubai International Financial Centre) wills registry (available even to non-residents of the UAE) or with the ADGM (Abu Dhabi Global Market) courts. The overall Dubai tax system is explained in Is there no tax in Dubai (UAE)?.

Main countries with inheritance or estate tax

Among popular relocation destinations, the following countries have inheritance or estate tax. The US taxes foreign assets once a person is domiciled in the US (center of life plus intention to stay permanently), and the UK does so once a person has lived in the UK for 10 of the previous 20 tax years. As a result, inheritance tax may be charged both in Japan and in the destination country.

Particular care is needed if you are considering moving to the US. If you obtain US permanent residence (a green card) and move the center of your life to the US, US estate tax extends to your worldwide assets, including assets in Japan; and for Japanese nationals, Japanese inheritance tax will also apply to foreign assets until the 10-year condition is met.

When foreign assets fall outside Japanese inheritance tax: both decedent and heir for 10 years

Where the decedent is a Japanese national, whether Japanese inheritance tax applies to foreign assets depends on whether the decedent and each heir "had a domicile in Japan within the 10 years before the inheritance", and on the heir's nationality. The statutory rules (Article 1-3 of the Inheritance Tax Act) can be summarized as follows.

The key point is that both the decedent and the heir must satisfy the 10-year condition. For example, if a parent and child leave Japan together in April 2027 and never have a domicile in Japan again, foreign assets fall outside Japanese tax only for an inheritance occurring after April 2037. If a temporary return to Japan becomes long and the center of your life is judged to have been in Japan during that time, the 10 years are counted from then.

This 10-year rule has applied to inheritances on or after April 1, 2017 (previously it was 5 years). Gift tax has the same structure (Article 1-4 of the Inheritance Tax Act): if neither the giver nor the recipient has had a domicile in Japan within 10 years, gifts of foreign assets fall outside Japanese gift tax.

Cases by family living arrangement

If you acquire a foreign nationality, and if you are a foreign national

For Japanese nationals: even if a parent acquires a foreign nationality, the 10 years still apply

A Japanese national who voluntarily acquires a foreign nationality loses Japanese nationality (Article 11 of the Nationality Act; for details see Countries that allow dual citizenship). So if the decedent (the parent) acquires a foreign nationality, do foreign assets fall outside Japanese tax without waiting 10 years? They do not.

Under the Inheritance Tax Act, a "non-resident decedent" is a person who had no domicile in Japan at the time of the inheritance and who falls under either of the following.

• A person who had a domicile in Japan within the 10 years before the inheritance but did not have Japanese nationality at any time during that period
• A person who had no domicile in Japan within the 10 years before the inheritance

Someone who lived in Japan as a Japanese national and acquired a foreign nationality after leaving had Japanese nationality while domiciled in Japan, so the first category does not apply. In the end they must wait until they meet the second category, "no domicile in Japan within 10 years", so on the parent's side, changing nationality is not a shortcut.

If the child is a foreign national

If the heir (child) living abroad does not have Japanese nationality, the child's 10 years are not tested; the only question is whether the decedent qualifies as a non-resident decedent (or a foreign-national decedent). If the Japanese-national parent has had no domicile in Japan for more than 10 years, foreign assets received by the foreign-national child are outside Japanese inheritance tax. Conversely, if the parent lives in Japan or left Japan less than 10 years ago, Japanese inheritance tax applies to foreign assets even if the child is a foreign national.

A child who holds both a foreign nationality and Japanese nationality (dual nationality) is treated as "having Japanese nationality", so the 10-year condition also applies on the child's side.

If you are (and always were) a foreign national

A person who never had Japanese nationality during their time living in Japan (a foreign national) becomes a non-resident decedent as soon as they leave Japan (for inheritances on or after April 1, 2018). In addition, a foreign national living in Japan under a work-type or other status of residence listed in Appended Table I of the Immigration Control Act who dies in Japan is a foreign-national decedent, regardless of how long they lived in Japan (from April 1, 2021). When inheriting from a foreign-national decedent or a non-resident decedent, foreign assets received by the following heirs are not subject to Japanese inheritance tax: (1) people living in Japan as temporary residents; (2) people without Japanese nationality living abroad; and (3) Japanese nationals living abroad who have had no domicile in Japan for more than 10 years. An heir who has Japanese nationality and lived in Japan within 10 years is taxed on foreign assets even if living abroad. People with Permanent Resident, Spouse or Child of Japanese National, or Long-Term Resident status (statuses listed in Appended Table II) are not foreign-national decedents.

If a child living abroad inherits from a parent living in Japan

If the parent lives in Japan, heirs living abroad are also taxed on assets in Japan and abroad, and where a return is required they appoint a tax agent and file. Foreign-national heirs and heirs living abroad often cannot obtain a Japanese seal registration certificate, so for the estate division agreement they use signature certificates or affidavits from a Japanese embassy or consulate or a local notary. If you inherit real estate in Japan, registering the inheritance within 3 years of learning that you acquired the property by inheritance is mandatory. US citizens and US residents who receive inheritances or gifts totaling more than US$100,000 in a year from non-US individuals and others must report them to the IRS (Form 3520), even though no US tax is due. Obtaining family register (koseki) certificates and having documents authenticated can be done from abroad (Obtaining koseki certificates from abroad (in Japanese)).

How Japanese inheritance tax is calculated, and the statutory categories

Whether an asset is "located in Japan" is determined by the type of asset (Article 10 of the Inheritance Tax Act). It depends on the type of asset, not on where the account is held.

The basic deduction for Japanese inheritance tax is JPY 30 million + JPY 6 million × the number of statutory heirs, and the tax rates range from 10% to 55% in eight brackets, applied to the amount corresponding to each statutory share.

For example, if a parent living in Japan dies, the only statutory heir is one child, and that child inherits JPY 300 million in deposits, investment trusts and similar assets, the basic deduction is JPY 36 million, the total taxable estate is JPY 264 million, and the tax is JPY 264 million × 45% − JPY 27 million = JPY 91.8 million (before various tax credits). This calculation does not change even if the child lives abroad or is a foreign national.

The four statutory categories

Article 1-3 of the Inheritance Tax Act divides heirs into the following four categories.

The terms mean the following. A temporary resident is a person who, at the time of the inheritance, lives in Japan under a work-type or other status of residence in Appended Table I of the Immigration Control Act and whose periods of domicile in Japan within the previous 15 years total 10 years or less. A foreign-national decedent is a decedent who was living in Japan under an Appended Table I status of residence at the time of the inheritance. A non-resident decedent is explained in the section above.

People taxed only on assets in Japan (limited liability taxpayers) can deduct only debts related to assets in Japan and similar items, and cannot deduct funeral expenses. They also cannot use the minor's credit or the disability credit. Because the disability credit is available only to heirs domiciled in Japan, heirs living abroad who are taxed on assets in Japan and abroad (non-resident taxpayers with unlimited liability) cannot use it either. Heirs living abroad who file a Japanese inheritance tax return must appoint a family member, tax accountant or other person living in Japan as their tax agent.

Pitfalls when trying to reduce inheritance tax by moving abroad

Moving abroad does little for business owners and people whose wealth is mainly real estate

Even if the 10-year condition is met, assets in Japan remain subject to Japanese inheritance tax. Shares in your own company (a Japanese company) are assets in Japan as long as the company's head office is in Japan, and the same is true of Japanese real estate. If most of your wealth consists of shares in your own company or Japanese real estate, moving abroad changes your inheritance tax only a little. Also, if you continue to run your company in Japan after moving abroad, the center of your life may be found to be in Japan. Passing on shares in your own company should be considered with a tax accountant as a business succession issue (successor, share valuation, the business succession tax relief, etc.), separately from relocation. How Japanese bank accounts are treated after moving abroad is explained in What happens to your Japanese bank accounts when you move abroad?

Japan's exit tax and its tax deferral

People who, when leaving Japan, hold securities such as listed shares, unlisted shares (including shares in their own company) and investment trusts worth JPY 100 million or more in total, and who had a domicile or residence in Japan for more than 5 years within the 10 years before departure, are charged income tax on unrealized gains at departure (the exit tax). The rate is 15.315% (including the special reconstruction income tax), the same as for capital gains on shares; for example, unrealized gains of JPY 200 million result in about JPY 30.63 million of tax.

When a person holding JPY 100 million or more in securities gives securities to someone living abroad, income tax is likewise charged on the giver's unrealized gains. When an heir living abroad inherits them, the tax is charged as the deceased's income tax, and the heirs file the final return on the deceased's behalf.

The exit tax can be deferred for 5 years (up to 10 years if extended) if requirements such as appointing a tax agent and providing collateral are met. However, if a person receiving this deferral dies or makes a gift, that person is deemed to "have had a domicile in Japan within 10 years" regardless of how long ago they actually left, and foreign assets become subject to Japanese inheritance or gift tax (Article 1-3, paragraph 2 and Article 1-4, paragraph 2 of the Inheritance Tax Act). A child living abroad who received securities from a parent by gift or inheritance under the deferral may be treated the same way at the time of their own inheritance or gift (except a child who had no domicile in Japan within the 10 years before that gift or inheritance).

Inheritance tax in your destination country and relief from double taxation

If your destination country levies inheritance or estate tax, as the US and the UK do, the same assets may be taxed both in Japan and in that country. In Japan, when foreign inheritance tax has been charged on assets located outside Japan, the credit for inheritance tax on foreign assets (Article 20-2 of the Inheritance Tax Act) allows that tax to be deducted from Japanese inheritance tax. The deductible amount is capped and is calculated for each heir as "that heir's inheritance tax × the proportion of foreign assets subject to foreign inheritance tax". The proportion is the share of the foreign assets subject to foreign inheritance tax in the assets acquired by that heir (those included in the taxable value calculation). Foreign inheritance tax charged on assets located in Japan (such as Japanese real estate or deposits) cannot be deducted under this credit. Japan's only inheritance tax treaty is the Japan–US estate tax treaty (in force since 1955); double taxation with the UK and other countries is adjusted under each country's domestic law.

If you directly hold US shares or US real estate

Even people who are neither US citizens nor US residents must file a US estate tax return if their US-situated assets, such as shares in US companies or US real estate, exceed US$60,000 (IRS). Their exemption is effectively only US$60,000, and estate tax of up to 40% is charged on the excess. Even if you move to a country with no inheritance tax, the US estate tax issue remains if you directly hold US shares. The Japan–US estate tax treaty may increase the credit available, so people with significant US assets should check with professionals in both Japan and the US.

Frequently asked questions

If I move to a country with no inheritance tax, will my inheritance tax be zero?

No. Where both decedent and heir are Japanese nationals, Japanese inheritance tax applies to foreign assets too, unless both have had no domicile in Japan for more than 10 years. Even after 10 years, Japanese inheritance tax applies to real estate in Japan, deposits with banks in Japan and shares in Japanese companies.

Are the 10 years counted from the date I deregistered my resident record?

It is judged by whether the center of your life was in Japan, not by your resident registration. Even if you have moved your resident record out, you may be found to have a domicile in Japan if the center of your life remains there. The test is whether you "had a domicile in Japan within the 10 years before the inheritance began".

What if only the parent lives abroad and the child lives in Japan?

A Japanese-national child living in Japan is a resident taxpayer with unlimited liability, so Japanese inheritance tax applies to everything they receive (in Japan and abroad), no matter how many years the parent has lived abroad.

Does a temporary return to Japan restart the 10 years?

There is no rule based solely on the number of days spent in Japan. For a short temporary return, the center of your life is normally judged to remain abroad. However, if you live in Japan for a long period and your family, work and home are found to have moved back to Japan, you will be treated as having had a domicile in Japan during that time, and the 10 years are counted from then. Keeping records of the number of days, purpose and place of stay for each return makes it easier to explain.

Is a lifetime gift to a child living abroad free of Japanese gift tax?

Gift tax has the same structure as inheritance tax. Where both parent and child are Japanese nationals, gifts of foreign assets are outside Japanese gift tax if neither has had a domicile in Japan within 10 years. If either has lived in Japan within 10 years, Japanese gift tax also applies to gifts of foreign assets (if the child is a foreign national living abroad, only the parent's 10 years are tested). When a person holding JPY 100 million or more in securities gives securities to a child living abroad, the parent may also be charged the exit tax (income tax on unrealized gains).

What happens if I return to Japan after 10 years?

Japanese inheritance tax is determined by whether a person is domiciled in Japan at the time of the inheritance. If the decedent returns to Japan, establishes a domicile and then dies, all assets in Japan and abroad are subject to Japanese inheritance tax. If a Japanese-national heir returns to Japan and establishes a domicile, the assets that heir receives are also taxable whether in Japan or abroad. The 10-year condition must continue to be met up to the time of the inheritance.

Summary: check Japan's 10-year rule before comparing destination tax systems

Many countries have no inheritance tax, including Australia, New Zealand, Singapore, Hong Kong, Malaysia and the UAE. However, where decedent and heir are both Japanese nationals, Japanese inheritance tax stops applying to foreign assets only when both have had no domicile in Japan for more than 10 years, and the test is applied heir by heir. Assets in Japan remain taxable after that, and if a person receiving the exit tax deferral dies, foreign assets are not excluded. If your destination, like the US or the UK, has inheritance tax, you will be taxed there as well. Deciding first who in your family will live in which country and when, and then comparing destination tax systems, makes the decision easier.

What to organize before consulting a tax accountant

• For each family member (spouse, children): country of residence, nationality and date of departure from Japan (or planned date)
• Types and locations of assets (Japanese real estate, shares in your own company, listed shares, overseas deposits and shares, US assets)
• The total market value and unrealized gains of your securities (whether JPY 100 million or more)
• Whether you have a will, and whether you will make one in your destination country
• Inheritance or estate tax, income tax and capital gains tax in the candidate destination countries

References (primary sources)

• e-Gov: Inheritance Tax Act (Articles 1-3, 1-4, 10 and 20-2)
• National Tax Agency: Tax Answer No. 4138 — When an heir lives abroad
• National Tax Agency: Tax Answer No. 4432 — When a gift recipient lives abroad
• National Tax Agency: Tax Answer No. 4152 — Calculating inheritance tax
• National Tax Agency: Tax Answer No. 4155 — Inheritance tax rates
• National Tax Agency: Exit tax system
• National Tax Agency: Tax Answer No. 1478 — Special rules on capital gains when leaving Japan
• National Tax College: Zeidai Journal (Japan–US estate tax treaty)
• KPMG: 2018 tax reform (definition of non-resident decedent)
• KPMG: 2021 tax reform (foreign-national decedent)
• PwC Worldwide Tax Summaries: Inheritance and gift tax rates
• IRS: What's new — Estate and gift tax
• IRS: Some nonresidents with U.S. assets must file estate tax returns
• UK government: Inheritance Tax if you're a long-term UK resident
• New Zealand Inland Revenue: Gift duty abolition
• Hong Kong Inland Revenue Department: Estate Duty
• Portuguese Tax Authority: binding ruling on stamp duty
• Austrian Economic Chamber: gift notification (Schenkungsmeldegesetz)
• PwC Worldwide Tax Summaries: Vietnam (personal income tax on inheritances)
• PwC Worldwide Tax Summaries: Spain (inheritance and gift tax)
• PwC Worldwide Tax Summaries: Thailand (inheritance tax)
• PwC Worldwide Tax Summaries: Other taxes by country (existence of inheritance and gift tax, month of last review)
• Estonian Tax and Customs Board: Estate
• PwC Cyprus (Mondaq): Inheritance tax
• Swedish government: bill on abolishing inheritance and gift tax (2004/05:97)
• IRS: Instructions for Form 3520
• Ministry of Justice: Mandatory registration of inheritance
• PwC Philippines: Estate tax amendments (2018)
• Withers: Inheritance and wills for non-Muslims in the UAE
• Dominica Citizenship by Investment Unit: Benefits
• Vanuatu Investment Promotion Authority: Low tax jurisdiction

The rules in this article are based on public information as of October 15, 2026 (including the National Tax Agency's laws and regulations as of April 1, 2026).