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International Comparison of Inheritance Tax System

 

Japan

U.S.A.

U.K.

Germany

France

Taxation method

Tax on legatee

Tax on bequest

Tax on bequest

Tax on legatee

Tax on legatee

Tax threshold
(Spouse and 3 children)
(3 children)


90 million yen
80 million yen


153.4 million yen
76.7 million yen


88.7 million yen
44.5 million yen


160.8 million yen
80.4 million yen


36 million yen
18 million yen

Minimum tax rate

10 %

37%(18 %)

40 %

7 %

5 %

Maximum tax rate

70 %

55 %(55%+5%)

30 %

40 %

Number of brackets

9

17(8)

1

7

7

(Notes) 1.

If the inheritors are a spouse and her/his three children, taxable amount would be minimized if the spouse obtains half of the bequest and the children equally share the balance of the bequest. If three children inherit the bequest, this tax threshold is applied when the children share an equal amount of the bequest.

2.

Since the U.S estate tax system is taking the unified tax credit ($202,050) , taxable estate to which the tax rates of 18% to 34% are applied is exempt from estate tax. 5% of estate tax is added on any transfer over $10,000,000 but not exceeding $17,184,000 (Estate tax rate becomes 60%).

3.

The tax rates for Germany and France in the table above are those applied when inheritors are the spouse or the children. The tax rate differs according to the relationship between the deceased and the inheritors. In case of the most distant relatives, the tax rate is 17-50 % in Germany and 60 % in France.

4. The figures in tax thresholds of foreign countries are converted into yen by the following exchange rates. U.S.A.: 1 dollar = 118 yen, U.K.: 1 pound = 192 yen, Germany: 1 mark = 67 yen, France: 1 franc= 20 yen.

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