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Cross-Border Estate Planning

Australia has no inheritance tax β€” but the country you live in might. Analyse your estate exposure, super death benefits, CGT on inherited assets, and dual-country will requirements.

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Inheritance Tax by Country

CountryInheritance Tax?RateThresholdOn AU Assets?
πŸ‡¦πŸ‡Ί Australiaβœ— None0%N/AN/A
πŸ‡¬πŸ‡§ UKβœ“ Yes (IHT)40%Β£325k (Β£500k with home)On worldwide assets of UK domiciled
πŸ‡ΊπŸ‡Έ USβœ“ Yes (Estate Tax)40%$13.6m (2024)On worldwide assets of US persons
πŸ‡©πŸ‡ͺ Germanyβœ“ Yes7–50%€400k spouse / €400k childrenOn assets in Germany + if resident
πŸ‡«πŸ‡· Franceβœ“ Yes5–45%€100k per childOn worldwide assets if resident 6/10 yrs
πŸ‡ΈπŸ‡¬ Singaporeβœ— None0%N/A β€” abolished 2008N/A
πŸ‡³πŸ‡Ώ New Zealandβœ— None0%N/AN/A