, '''estate tax''' and '''death duty''' are the names given to various Taxes which arise on the death of an individual. In United States tax law, there is a distinction between an estate tax and an inheritance tax: the former taxes the personal representatives of the deceased, while the latter taxes the beneficiaries of the estate. However this distinction does not apply in other jurisdictions. For example: if using this terminology in the UK, an inheritance tax would be equivalent to an estate tax.
- In some jurisdictions the term used is , and for historical reasons that term is used colloquially - although it is no longer correct legally - in the United Kingdom and some Commonwealth nations.
- In some jurisdictions, death gives rise to a charge to :
- --- Bermuda
- In some jurisdictions, death gives rise to a charge to ''' Capital Gains Tax :
- --- Canada . See Taxation In Canada .
::Where a jurisdiction has capital gains tax and inheritance tax (for example the United Kingdom) it is usual to exempt death from the capital gains tax.
- In some jurisdictions death gives rise to the local equivalent of (see Austria, below, for example). This was the model in the United Kingdom during the period before the introduction of Inheritance Tax in 1986, where estates were charged to a form of gift tax called Capital Transfer Tax. Where a jurisdiction has a gift tax and an estate tax (for example the United States at federal level) it is usual to exempt death from the gift tax. Also, it is common for inheritance taxes to share some features of gift taxes, by taxing some transfers which happen during lifetime rather than on death. The United Kingdom, for example, taxes "lifetime chargeable transfers" (usually gifts to Trusts ) to inheritance tax.
- Non-English speaking jurisdictions naturally use non-English terminology:
- --- Austria charges , which has some of the features of a Gift Tax .
- --- Belgium , a multilingual nation, uses the terms and '''successierechten''', taxes on beneficiaries which are collected at the federal level but distributed to the regional level.
- --- Czechia charges , taxes on beneficiaries.
- --- France uses the term , taxes on beneficiaries.
- --- Germany charges , a tax on beneficiaries.
- --- The Netherlands charges , a tax on beneficiaries.
- --- Switzerland has no / '''impôt successoral''' / '''imposta di successione''' at national level. However in the various cantons, three possibilities (a tax on the estate, a tax on the beneficiaries, or no tax) exist.
''This page is a modified page, which distinguishes not just between pages which would otherwise have the same name, but also between similar legal concepts which have different names in different jurisdictions.''
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