For high-net-worth individuals and global families, wealth isn’t just about capital—it’s about legacy. And when it comes to passing that legacy on to the next generation, inheritance tax can be a silent threat.
That’s why more investors are seeking second citizenship or residency in countries with no inheritance tax, allowing them to transfer wealth tax-efficiently while enjoying global mobility, asset protection, and lifestyle benefits. We explore the most attractive destinations in 2025 where expats can legally avoid inheritance tax, including both Citizenship-by-Investment (CBI) and Residency-by-Investment (RBI) options.
Why Inheritance Tax Matters When Choosing a Second Passport
Wealth Transfer Is Now a Global Strategy
According to Credit Suisse, over USD 15 trillion in global wealth is expected to transfer to the next generation by 2030. As governments face fiscal pressure, many are increasing inheritance and estate taxes to bridge budget gaps.
In the U.S., the federal estate tax tops out at 40%. In the UK, it’s 40% after a threshold of USD 379, 000.
Even modest inheritances can be significantly eroded.
How Inheritance Tax Undermines Your Legacy
Inheritance tax is often levied on the total value of a deceased person’s estate, including real estate, investments, and even gifts given shortly before death.
In some countries, rates rise to 50%, and heirs outside the immediate family can face severe tax penalties.
Second citizenship or residency in a tax-neutral country provides a legitimate, strategic route to preserve generational wealth—while unlocking visa-free travel, lifestyle perks, and business flexibility.
Countries with No Inheritance Tax for Expats and Investors
Let’s look at the most favorable jurisdictions where expats can legally avoid inheritance tax, grouped by how the tax regime applies.
Total Tax Freedom: No Inheritance, Estate, or Gift Taxes
These countries impose zero inheritance tax, no estate duties, and often no gift tax either—for residents, non-residents, and citizens.
🇦🇬 Antigua and Barbuda
- Inheritance tax: None
- Estate/gift tax: None
- Notes: No forced heirship; wealth passes tax-free to any beneficiary
- CBI available from USD 100,000
🇩🇲 Dominica
- Inheritance tax: None
- Estate/gift tax: None
- Notes: Testamentary freedom with zero death duties
- CBI available from USD 100,000
🇬🇩 Grenada
- Inheritance tax: None
- Estate/gift tax: None
- Notes: Real estate transfer tax applies only on sale—not on inheritance
- CBI available from USD 150,000
🇰🇳 Saint Kitts and Nevis
- Inheritance tax: None
- Estate/gift tax: None
- Notes: No forced heirship; no succession taxes
- CBI available from USD 250,000
🇱🇨 Saint Lucia
- Inheritance tax: None
- Estate/gift tax: None
- Notes: No restrictions on heirs, no hidden fees
- CBI available from USD 100,000
🇻🇺 Vanuatu
- Inheritance tax: None
- Estate/gift tax: None
- Notes: Also no income or capital gains tax; testamentary freedom
- CBI available from USD 130,000
No Inheritance Tax, But Stamp Duties or Low Fixed Rates May Apply
These countries do not impose traditional inheritance tax but may charge low flat duties or apply rates only to non-relatives.
🇲🇹 Malta
- Inheritance tax: None
- Stamp duty: 5% on inherited Maltese real estate
- Exemptions: Spouses and children often exempt or pay reduced rates
- Forced heirship: Yes (reserved shares for close family)
- CBI available via naturalization by exception
🇵🇹 Portugal
- Inheritance tax: None
- Stamp duty: 10% on Portuguese assets, exempt for spouse and children
- Forced heirship: No
- RBI available via D7 visa and investment funds
🇭🇺 Hungary
- Inheritance tax: None for spouses, children, parents, or siblings
- Flat rate: 18% for others; 9% for real estate
- Forced heirship: Yes (limited to a financial claim)
- RBI previously available; future program under review
🇲🇪 Montenegro
- Inheritance tax: 0% for immediate family, 3% flat rate for others
- Gift tax: Mirrors inheritance tax
- Forced heirship: Yes
- CBI program closed in 2022
🇬🇷 Greece
- Inheritance tax: 1%–10% for spouse/children (with USD 175,000 exemption), up to 40% for others
- Gift tax: Same brackets
- Forced heirship: Yes
- Golden Visa available from USD 292,000
🇹🇷 Turkey
- Inheritance tax: 1%–10% for family, up to 30% for non-family
- Exemptions: Spouse/children exempt on first USD 24,888 (TRY 1 million)
- Gift tax: 10%–30%, halved for family
- Forced heirship: Yes
- CBI available from USD 400,000 (real estate)
What Expats Need to Know About Local Law, Residency, and Heirs
When Are You Taxed on Worldwide Assets?
Many countries only apply inheritance tax to assets located within their borders. However, some (like Turkey or Greece) may tax global assets if the deceased or heir is a resident or citizen.
If you become domiciled in a country, your entire worldwide estate may fall under its tax net—unless carefully structured.
Forced Heirship Can Limit Your Freedom
Countries like Greece, Malta, Montenegro, Turkey, and Hungary enforce forced heirship laws. These require a fixed portion of your estate to go to your spouse, children, or parents—regardless of your will. However, many common-law countries (e.g., Dominica, Saint Lucia, Antigua) allow full testamentary freedom.
Are Expats Treated Differently?
Most of the countries listed treat expats the same as locals for inheritance purposes. The deciding factor is often the location of the assets, not your nationality. For example:
- If you leave property in Greece to your adult child in the US, Greek tax still applies.
- If you leave property in Grenada, no inheritance tax applies—no matter who inherits it.
Top Picks by Wealth Planning Scenario
| Goal | Recommended Country | Why |
|---|---|---|
| Pass family wealth tax-free | Saint Kitts, Grenada, Dominica | No inheritance/gift/estate taxes; no forced heirship |
| EU access + low/no inheritance tax | Malta, Portugal, Hungary | Tax-neutral or exempt for family heirs |
| Asset protection with lifestyle perks | Antigua, Vanuatu, Saint Lucia | No succession taxes and strong CBI benefits |
| Property-based investment with low tax | Montenegro, Turkey | Low fixed inheritance rates; family-friendly exemptions |
Where to Anchor Your Legacy
Inheritance tax can silently chip away at a lifetime of success. But with the right second citizenship or residency, your wealth can pass intact and tax-free to your heirs.
If you’re building a global life—whether for lifestyle, mobility, or legacy—don’t let poorly structured succession laws catch you off guard. Carefully choosing a country with no inheritance tax could save your family hundreds of thousands of dollars.
Secure Your Legacy with Expert Support
At Next Generation Equity, we specialize in guiding clients through second citizenship and residency programs with a strong focus on tax efficiency and wealth transfer. Let us help you build a cross-border legacy that’s not only secure—but tax-optimized.
Contact us today to explore your second citizenship options in jurisdictions with zero inheritance tax.
