Crypto inheritance taxes —
by jurisdiction.
Tax treatment of inherited crypto varies dramatically by country. Understand the rules, optimize your structure, avoid surprises.
Last updated · March 2026
Key Tax Events in the Vault Lifecycle
| Step | Tax Event | Who Pays | Note |
|---|---|---|---|
| Create vault | None | — | Transfer between own wallets |
| Deposit assets | None | — | No change in ownership |
| Check-in | None | — | Administrative action |
| AAVE yield accrual | Income | Owner | Taxable as earned |
| Dead man’s switch triggers | None | — | Condition not yet fulfilled |
| Execute claim | Key event | Varies | FMV snapshot, cost basis set |
| Withdraw | Receipt | Beneficiary | Reported in declaration |
| Sell after receiving | Capital gains | Beneficiary | Gain from cost basis |
Crypto Inheritance Tax Rates by Country
Comparison for 2026
| Country | Best Qualification | Family Rate | Non-Family Rate | Note | Source |
|---|---|---|---|---|---|
| United States | Inheritance (stepped-up basis) | 0% up to $15M/person | 0% up to $15M, then 40% | OBBBA 2025 — permanent, no sunset | IRC §1014, §2010; One Big Beautiful Bill Act (2025) |
| Russia | Gift (close relatives) | 0% | 13% income tax | Art. 217 Tax Code | НК РФ ст. 217 п. 18.1; ст. 224 п. 1 |
| Germany | Inheritance (Freibetrag) | 0% up to €400K (children) | 30–50% | Spouses: €500K exemption | ErbStG §§15–19; §16 Freibeträge |
| France | Inheritance (abattement) | 0% up to €100K (children) | 60% | Spouses fully exempt | CGI Art. 777, 779; Loi 2007-1223 |
| UAE | Any (0% on everything) | 0% | 0% | No income, inheritance, or gift tax | Federal Decree-Law No. 47/2022 (Corporate Tax); no inheritance tax legislation |
| Switzerland | Inheritance (cantonal) | 0% in most cantons | 0–50% | Varies by canton and relationship | Cantonal tax laws (e.g. ZH §§ 1–25 ESchG; ZG: no inheritance tax) |
| Singapore | Any (no estate duty) | 0% | 0% | Estate duty abolished 2008 | Estate Duty (Abolition) Act 2008 |
| Malta | Any (no inheritance tax) | 0% | 0% | 5% stamp duty on certain property | Duty on Documents and Transfers Act (Cap. 364) |
| Portugal | Inheritance | 0% | 10% stamp duty | Direct line exempt | Código do Imposto do Selo, Art. 1°, Tabela Geral |
Cost Basis
INHERITANCE
Stepped-Up Basis
Cost basis equals fair market value at the date of death. All prior unrealized gains are eliminated. Available in the US (IRC §1014) and similar rules in most jurisdictions. The single largest tax advantage of inheritance over gifting.
GIFT
Carry-Over Basis
Cost basis equals the donor's original purchase price. All unrealized gains transfer to the recipient. Applies to lifetime gifts in the US. In some jurisdictions (Russia, UAE), gifts between close relatives are fully tax-free regardless of basis.
HeirVault can attach claim-time fair market value snapshots when pricing data is available. Current reports use configured pricing sources such as CoinGecko and mark missing or incomplete valuation data as partial or unavailable for professional review.
How HeirVault Helps
Accurate tax documentation can be the difference between a smooth inheritance and a costly review. HeirVault helps assemble draft claim-time FMV evidence and multi-currency reports for beneficiaries in different jurisdictions.
Current FMV snapshots use configured pricing sources such as CoinGecko. Reports preserve the available snapshot source and timestamp, and they explicitly flag partial or unavailable valuation data instead of treating missing prices as final.
Tax reports are available in PDF for filing and JSON for programmatic use. CSV exports are compatible with popular tax services including Koinly, CoinTracker, and TaxBit.
Disclaimer: This guide is for informational purposes only and does not constitute tax, legal, or financial advice. It is not a substitute for consultation with a qualified tax professional, CPA, or attorney. Tax laws change frequently and vary significantly by jurisdiction. HeirVault is a technology platform and does not provide tax, legal, or financial advisory services. Always consult a licensed professional before making decisions based on this information.
Jurisdiction: The tax rates and rules presented cover the United States, Russia, Germany, France, UAE, Switzerland, Singapore, Malta, and Portugal. They reflect the legislation in effect as of March 2026. Rates and exemptions may differ based on your specific circumstances, residency status, and relationship to the deceased. This guide does not cover all jurisdictions or all possible scenarios.
Frequently Asked Questions
What is stepped-up basis for crypto?
In the US, inherited assets receive a stepped-up cost basis equal to the fair market value at the date of death. This eliminates all prior unrealized capital gains. For example, if you bought Bitcoin at $1,000 and it's worth $100,000 at death, your heirs' cost basis is $100,000 — no tax on the $99,000 gain. The OBBBA (2025) preserved this benefit.
Is gifting crypto better than inheritance for tax purposes?
It depends on your jurisdiction. In the US, inheritance is usually better because heirs get a stepped-up basis, while gifts carry over the donor's original basis. In Russia, gifts between close relatives are tax-free (0% vs 13% for non-relatives). In the UAE and Singapore, both are tax-free.
Can I face double taxation if my heirs live in different countries?
Potentially yes. Each beneficiary pays taxes according to their own jurisdiction. Double Tax Treaties (DTTs) between countries may provide relief. HeirVault generates multi-currency tax reports and flags potential conflicts, but we recommend consulting an international tax advisor for cross-border situations.
What is CARF and how does it affect crypto inheritance?
CARF (Crypto-Asset Reporting Framework) is an OECD standard for automatic exchange of crypto transaction data between tax authorities. Most EU countries are implementing it by 2026, with UAE following in 2027. While CARF primarily targets exchanges, it increases the importance of accurate record-keeping for all crypto transfers including inheritance.
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