· Updated By The HelloHQ team

No Estate Tax Is Not the Same as No Estate Problem

Singapore, Malaysia, China and Indonesia have no estate tax. The US exemption is now US$15 million and permanent, and Taiwan is reviewing how lifetime gifts are taxed. Tax is only one of three ways an inheritance fails.

Ask a family in Singapore, Kuala Lumpur, Shanghai or Jakarta about estate tax and the answer is usually a relieved shrug. There isn't one.

That is true, and it is the least important fact in the conversation.

An inheritance can fail in three different ways. Tax takes a share. Law decides who gets what, whatever you intended. Liquidity determines whether the estate can pay its debts, settle its costs and move assets before they freeze. Four of the six markets in this series have no tax problem. Every one of them has the other two.

Estate tax is the cost of the transfer. Succession law and liquidity decide whether the transfer happens at all.

Where the estate tax is, and isn't

Jurisdiction Estate or inheritance tax What replaces it as the real constraint
Singapore None for deaths on or after 15 February 2008 Foreign assets and foreign heirs can still trigger other countries' rules
Malaysia None that we found Faraid for Muslim estates; Wills Act 1959 for non-Muslims; frozen estates
China None; a 2004 draft never took effect Civil Code succession rules; deed and registration taxes can arise on transfers
Indonesia None; inheritance is not income Three parallel regimes (adat, Islamic, civil); land transfer duty
Taiwan Yes: 10%, 15% or 20% above an exemption of NT$13.33 million (2025 parameters) Forced heirship; a pending amendment on lifetime gifts
United States Yes: 40% top rate above US$15 million per person from 2026, indexed and with no sunset State estate and inheritance taxes; portability; beneficiary designations

Taiwan: a ruling waiting for a law

Taiwan taxes estates and gifts at three rates: 10%, 15% and 20%. The 2025 parameters, indexed by the Ministry of Finance rather than reformed, set the estate exemption at NT$13.33 million and the annual gift exemption at NT$2.44 million per donor. The Civil Code adds forced heirship: reserved portions for spouses, descendants and parents, and a smaller share for siblings and grandparents.

The pending issue is a Constitutional Court judgment from 2024 (Judgment 113-Hsien-Pan-11) on how the Estate and Gift Tax Act treats certain transfers, which legislators are expected to answer with an amendment. We could not find the text of an enacted amendment as of this writing. The practical point does not need the details: in Taiwan, the timing of lifetime gifts relative to death is something lawmakers are actively reviewing, and plans built on gifting should be checked against the amendment when it arrives.

The United States: permanence, not safety

The One Big Beautiful Bill Act, signed 4 July 2025, set the federal estate, gift and generation-skipping exemption at US$15 million per person from 2026 (US$30 million per couple), indexed for inflation, with no scheduled sunset. The annual gift exclusion for 2025 is US$19,000 per donee.

Two cautions. First, "permanent" in tax law means "until Congress changes it". The 2025 rush to use an expiring exemption is gone, but the urgency was real, and it was a reminder that exemption levels follow politics. Second, state-level estate and inheritance taxes, which we did not research, can bite well below the federal level.

Malaysia: the frozen estate

The most striking numbers in this research are not tax numbers. They describe what happens when no one plans.

In 2025, Amanah Raya cited about RM65 billion of unclaimed or stuck assets in Malaysia. A separate July 2025 report put frozen Islamic-inheritance assets above RM90 billion, including roughly RM60 billion of real estate held up at land offices, and noted that only about 5% of Malaysians have done estate planning. The two figures differ in scope and cut-off date. Read them as "tens of billions of ringgit", not as a precise total.

For Muslim estates, faraid fixes the shares. For non-Muslims, the Wills Act applies. Hibah (lifetime gift), wasiyyah (bequest) and nominations are the flexible tools. In every case, assets without documents stay put. Unclaimed money held for 15 years moves to government revenue.

China and Indonesia: the law decides first

China has no inheritance, estate or gift tax. Succession is governed by the Civil Code, and a will matters. Transfers outside the statutory heirs can attract a deed tax of roughly 1% to 3%. Where families use trusts for succession, the income-tax treatment of the trust matters as much as the succession law, and for Chinese residents that treatment was about to change (see the update below).

Indonesia has no inheritance tax, and inheritance is not taxable income. But three legal systems run in parallel: adat (customary), Islamic law, and the Civil Code. Which one applies depends on the family. A transfer of land incurs a duty, with a higher threshold for inheritance.

The planning fundamentals

Sound private wealth management treats estate planning as part of the Investment Policy Statement, not as an add-on. Three ideas carry over directly.

Estate liquidity. The estate must be able to pay costs and taxes without a forced sale. In practice: how much of the estate is cash, listed securities or insurance, and how much is a family business or a property that cannot be sold quickly?

Transfer timing. Giving early moves future growth out of the estate, at the cost of control and of someone else's tax position. Taiwan's pending amendment shows that lawmakers are looking closely at giving close to death.

Match the plan to the heirs. The IPS has a "unique circumstances" section. Heirs in different countries, a family business, a child with special needs, and a spouse with a different religion are all unique circumstances that change the right structure.

Practical implications

  1. Write down which law governs each asset. Property: the law of where it sits. Bank accounts: the account's jurisdiction. Shares in a company: the company's. Many families discover that one person's estate runs under three legal systems.
  2. Update nominations and beneficiaries. Retirement-fund nominations, insurance policies and joint accounts usually pass outside the will. They are the most commonly out-of-date documents in a family.
  3. Test the liquidity. Total the likely costs of settlement and any tax. Compare it to the cash and quickly saleable assets. If there is a gap, close it on purpose.
  4. Put gifts on a calendar. In Taiwan, a gift's timing relative to death is under legislative review. In the US, the annual exclusion is a use-it-each-year resource.
  5. Leave a map. A one-page list of institutions, account types, document locations and the person who knows. It is the cheapest way to avoid becoming part of the frozen-estate statistic.

Update, October 2026: what the following year added

Taiwan answered the ruling. The Executive Yuan approved an amendment to the Estate and Gift Tax Act on 30 July 2026, and a secondary source reports that the Legislative Yuan passed it on 21 August 2026; we could not confirm the effective date. As reported: gifts made within two years before death to a spouse, heirs, and their spouses are pulled back into the estate, and the recipients bear their proportionate share of the tax. Gifts to a spouse are treated as still owned by the decedent when computing the spousal surplus deduction. The lesson is general: a gift made in the last two years looks like a will, and regulators price it that way.

The US figure was confirmed. The IRS confirmed the US$15 million basic exclusion for decedents dying in 2026, and Cerulli projected US$124 trillion passing between generations through 2048 (reported via 24/7 Wall St, 30 September 2026).

China moved on trusts. The offshore trust rules of 24 July 2026 change the income-tax treatment of trusts for PRC-resident contributors. See the border stopped protecting your income.

What we could not confirm

The body of this post reflects what was known on 29 July 2025; later developments are in the update section. The Taiwan amendment's effective date, and its exact scope for gifts to heirs' spouses, rest on a secondary relay of a Ministry of Finance notice. Malaysia's frozen-estate figures come from search summaries of paywalled articles and conflict between sources. We did not research US state-level estate taxes, the position of non-resident aliens, or Indonesia's regional land-transfer thresholds in depth. This is not legal or tax advice.

Sources

Topics

Succession Cross-border

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