Crypto Inheritance Laws by Country: US, UK, EU, UAE, and Beyond

Cryptocurrency inheritance is governed by the laws of the jurisdiction where the deceased was domiciled — not where the blockchain is hosted. Since blockchains are borderless but tax authorities are not, inheriting crypto can trigger obligations in one country that do not exist in another.

This guide covers how the major jurisdictions treat inherited digital assets, including tax rates, exemptions, forced heirship rules, and practical considerations for heirs and estate planners.

United States

Estate Tax

The US imposes a federal estate tax on the total value of a deceased person's assets, including cryptocurrency. Under the OBBBA (One Big Beautiful Bill Act) of 2025, the estate tax exemption is approximately $15 million per individual. Estates below this threshold owe no federal estate tax.

Assets exceeding the exemption are taxed at rates up to 40%. Some states impose additional estate or inheritance taxes with lower thresholds — New Jersey, for example, taxes inheritances above $25,000 for non-immediate family members.

Stepped-Up Cost Basis

One of the most significant advantages of inheriting crypto in the US is the stepped-up cost basis. The heir's cost basis is reset to the fair market value at the date of death. If the deceased bought Bitcoin at $1,000 and it was worth $95,000 at death, the heir's cost basis is $95,000. If they sell immediately, they owe zero capital gains tax.

Reporting Requirements

Executors must file Form 706 (Estate Tax Return) if the estate exceeds the exemption. Heirs must report any subsequent gains or losses on Schedule D of their tax return. Crypto-to-crypto swaps are taxable events.

United Kingdom

Inheritance Tax

The UK imposes Inheritance Tax (IHT) at a flat rate of 40% on estates exceeding the nil-rate band of GBP 325,000. An additional residence nil-rate band of GBP 175,000 may apply if a home is passed to direct descendants.

HMRC has confirmed that cryptocurrency is treated as property for IHT purposes. The estate must be valued at the date of death, and the executor is responsible for paying IHT before distributing assets.

Capital Gains

Unlike the US, the UK does not provide a full stepped-up basis. Instead, the heir's cost basis is the market value at the date of death, and Capital Gains Tax (CGT) applies to any subsequent appreciation. CGT rates are 10% (basic rate) or 20% (higher rate) for crypto, with an annual exemption of GBP 3,000.

Probate

Crypto held in self-custody is part of the estate and subject to probate. If the deceased used a centralized exchange, the executor must contact the exchange to transfer or liquidate the assets.

Germany

Inheritance Tax

German inheritance tax rates vary from 7% to 50% depending on the heir's relationship to the deceased and the value of the inheritance. Spouses receive an exemption of EUR 500,000, children EUR 400,000, and grandchildren EUR 200,000.

Capital Gains

Germany exempts crypto held for more than one year from capital gains tax. Importantly, the holding period transfers to the heir. If the deceased held Bitcoin for 3 years, the heir inherits that holding period and can sell immediately with no capital gains tax.

This makes Germany one of the most favorable jurisdictions for crypto inheritance — if the assets were held long enough.

Forced Heirship

German law includes Pflichtteil (compulsory portion) rules. Children and spouses are entitled to at least 50% of their statutory inheritance share, regardless of what the will says. This applies to all assets, including crypto. A smart contract vault with custom allocation percentages should account for these requirements.

France

Inheritance Tax

French inheritance tax ranges from 5% to 45% depending on the relationship between the deceased and the heir. Direct-line heirs (children) receive an exemption of EUR 100,000 each. Unrelated parties pay 60% on everything above EUR 1,594.

Forced Heirship

France has strict forced heirship rules. Children cannot be disinherited. With one child, that child is entitled to 50% of the estate. With two children, 66.7%. With three or more, 75%. These rules apply to crypto just as they apply to any other asset.

Reporting

All crypto holdings must be declared to the French tax authority. Foreign exchange accounts holding crypto must be reported on Form 3916-bis. Non-compliance can result in penalties of EUR 1,500 per undeclared account.

Switzerland

Inheritance Tax

Switzerland has no federal inheritance tax. Cantonal rules vary significantly. Most cantons exempt spouses and direct descendants entirely. Some cantons (e.g., Schwyz, Obwalden) have no inheritance tax at all.

Wealth Tax

Switzerland does impose an annual wealth tax on all assets, including crypto. Rates vary by canton but are generally between 0.1% and 1% of total net worth. Inherited crypto must be included in the heir's wealth declaration from the date of inheritance.

Crypto-Friendly Environment

Switzerland's clear regulatory framework and crypto-friendly cantons (Zug, Zurich) make it a popular domicile for crypto holders planning succession. The Swiss Financial Market Supervisory Authority (FINMA) treats crypto as assets, providing legal certainty for estate planning.

United Arab Emirates

No Inheritance Tax

The UAE does not impose any form of inheritance or estate tax. This applies to all assets, including cryptocurrency. This makes the UAE one of the most favorable jurisdictions in the world for crypto succession.

DIFC Wills

Non-Muslim expatriates in the UAE can register a will with the DIFC (Dubai International Financial Centre) Wills Service Centre, which provides common-law-based succession rules. Without a registered DIFC will, Sharia inheritance law may apply by default, which allocates fixed shares to specific family members.

Practical Considerations

Despite the absence of tax, heirs still need to physically access the crypto. If assets are on a UAE-based exchange, the heir may need to present documentation to the exchange. A smart contract vault eliminates this dependency entirely.

Singapore

No Inheritance Tax

Singapore abolished estate duty in 2008. There is no inheritance or estate tax of any kind. This applies to all asset classes, including digital assets.

Capital Gains

Singapore does not impose capital gains tax. Crypto sold by heirs is generally not taxable unless the individual is classified as a trader (high-frequency, business-like activity).

Succession Act

If the deceased dies intestate (without a will), Singapore's Intestate Succession Act determines distribution. A surviving spouse receives half; the remainder goes to children equally. For Muslims, Sharia inheritance rules apply by default.

Practical Recommendations

Regardless of jurisdiction, these steps apply to every crypto holder planning their estate:

1. Know your domicile rules. Your tax obligations are determined by where you live, not where the blockchain is hosted.
2. Use the jurisdiction wizard to understand your specific situation.
3. Account for forced heirship. If you live in France, Germany, Spain, or another civil law country, your allocation percentages must comply with mandatory share rules.
4. Document the cost basis. Record purchase dates and prices for all holdings. Your heirs will need this information.
5. Set up a smart contract vault. A HeirVault dead man's switch works regardless of jurisdiction and ensures your heirs can claim without navigating local probate.
6. Review the tax guide for detailed strategies on minimizing inheritance tax burden.

The blockchain does not care about borders. But the tax authorities in your country certainly do. Plan accordingly.