The practical side of crypto inheritance is the same everywhere: find it, get into it, don’t get scammed. The legal side depends on where the person lived when they died. That decides who inherits if there’s no will, which document proves someone may act for the estate, and what tax is due.
These pages give the outline for three regions, with links to official sources. They’re a starting point for a conversation with a lawyer, notary or tax adviser, not a replacement for one.
- Crypto inheritance in the United States
How US estate tax, the step-up in basis, probate and RUFADAA apply to crypto, and what heirs and executors should know. With links to IRS sources.
- Crypto inheritance in the United Kingdom
How inheritance tax, capital gains tax, probate and the new digital assets law apply to crypto in the UK, and what HMRC expects from personal representatives.
- Crypto inheritance in the European Union
Which country's law applies to an inheritance in the EU, how the European Certificate of Succession helps heirs, why tax differs per country, and what DAC8 and MiCA change for crypto.
Things that are the same almost everywhere
- Crypto is part of the estate. Tax authorities and courts treat it as property, like shares or savings.
- Values are taken at the date of death. For estate or inheritance tax, and usually as the starting value for the heir’s own capital gains later.
- Companies want paperwork. A death certificate and an official document naming the executor or heirs. Without it, exchanges release nothing.
- Coins you can’t reach still count. If the estate knows crypto exists but can’t access it, tell the adviser. HMRC, for example, asks for an explanation and an estimated value rather than pretending it isn’t there.
Moved abroad, or assets in several countries?
Then more than one set of rules may apply, and specialist advice pays for itself. In the EU, the Succession Regulation decides which country’s inheritance law applies. Tax is separate, and two countries can both claim it; tax treaties sometimes help.