In short
Crypto is taxed on inheritance like other property, and each country does it differently. Canada, Australia and the United States have no inheritance tax at the federal or national level (the US has a federal estate tax only for very large estates). The United Kingdom, Germany, France and the Netherlands tax what heirs receive. The second question matters as much: what the heir’s later tax on a sale starts from. In the US, the UK and Canada it starts from the value at death. In Australia it starts from what the deceased originally paid.
This page compares the seven countries with their own guide on this site. Each row links to the full page, with the figures, official sources and a checklist for executors. Figures are for 2026. It is general information, not tax or legal advice.
Tax at death, country by country
| Country | Tax on the inheritance | What the heir’s later tax starts from |
|---|---|---|
| United States | No federal inheritance tax. The federal estate tax exclusion is $15 million per person in 2026; estates below it owe no federal estate tax. Several states have their own estate or inheritance tax with much lower thresholds. | Generally the value at the date of death (the “step-up”). Exception: assets in certain irrevocable trusts that are not part of the taxable estate keep their original basis. |
| United Kingdom | Inheritance tax of 40% above the nil-rate band of £325,000, frozen until April 2031. A residence nil-rate band of up to £175,000 can be added. What passes to a spouse or civil partner is usually exempt. | The value at the date of death. There is no capital gains tax on death. |
| Germany | The heir is taxed, not the estate, after an allowance: €500,000 for a spouse, €400,000 per child, €200,000 per grandchild (€400,000 if the parent has died), €100,000 per parent, €20,000 for siblings and others in tax class II. | For income tax the heir steps into the deceased’s shoes: coins held for more than a year can be sold tax-free. Inheritance tax is separate. |
| France | A spouse or PACS partner inherits free of tax. Children get €100,000 each tax-free and pay 5% to 45% above that. | The value declared at death becomes the heir’s purchase price for the 31.4% flat tax on later gains. |
| Netherlands | Erfbelasting on what each heir receives above an exemption: €828,035 for a partner and €26,230 per child in 2026, at 10% to 20% for partners and children, 18% to 36% for grandchildren and 30% to 40% for others. | Crypto counts at its market value on the day of death. There is no capital gains tax, because crypto is taxed yearly in box 3 instead. |
| Canada | No inheritance or estate tax. The person who died is treated as having sold their capital property, including crypto, just before death; the gain goes on the final return and half of it is taxable. Assets left to a spouse roll over untaxed. | The heir receives the coins at their value on the date of death and their own gain starts from there. The estate pays the tax, not the heir. |
| Australia | “There are no inheritance or estate taxes in Australia”, and death itself is not a capital gains tax event. | The heir takes over the deceased’s cost base and holding period. Bitcoin bought for $5,000 and inherited at $80,000 still counts as bitcoin that cost $5,000. |
In the European Union, the law of the country where the person habitually lived usually decides the inheritance, and inheritance tax is not set by the EU at all: each country has its own rules, and some have none. See crypto inheritance in the European Union.
Value at death or the deceased’s cost: why it matters
Two heirs can inherit the same bitcoin and face very different tax later. In the United States, the United Kingdom and Canada the heir’s starting point is the value at death, so gains made before death are not taxed again in the heir’s hands. In Australia the heir inherits the deceased’s original cost, so the tax on a later sale can be large, and the purchase records are as important as the keys. In Germany the question is the holding period: coins the deceased had held for more than a year can be sold without income tax.
In every country the starting point is a number that someone has to be able to prove. Record the value on the date of death, with the source, for each holding: valuing crypto at the date of death. In Australia and Canada also look for the purchase records, because without them the tax authority can treat the cost as zero.
Giving instead of leaving
The same crypto is taxed differently if you give it away while you are alive. In the United States a gift keeps your original cost for the recipient, while an inheritance gets the step-up. In the United Kingdom, Canada and Australia the gift is itself a taxable disposal. See give it now or leave it and putting crypto in a trust.
After the tax: getting at the crypto
Tax is only half of the process. Heirs also need the legal document that proves who may act: a grant of probate in the United Kingdom, letters testamentary in the United States, an Erbschein in Germany, an acte de notoriété in France, a verklaring van erfrecht in the Netherlands. Exchanges ask for it before they release anything: does crypto go through probate? For a wallet you hold yourself, no document is enough without the keys. The overview of the whole subject is in what happens to your crypto when you die.
For the people who must settle an estate, start with your first steps, then how to find out what crypto someone had. If the person who died lived in another country, check which country’s law applies. All the country pages are listed under crypto inheritance by country.
This page is general information, not tax or legal advice. Figures are for 2026; each country page links its official sources, with the date we last checked them.