KPMG Global Family Business Tax Monitor 2023 Report: 3 Highest Inheritance Tax Rates in APAC are South Korea 43%, Japan 21% & Thailand 3.6% and 3 Highest in Americas & Europe are United States 40%, United Kingdom 40% & Germany 23%
25th March 2023 | Hong Kong
KPMG, one of world’s largest audit, tax & advisory firm has released the Global Family Business Tax Monitor 2023 Report, providing key insights on family businesses around the world (Family Businesses Going Global, Family Offices & Managing Wealth, Philanthropy), tax rates & tax exemptions on family businesses by inheritance and by gifting in 57 countries, territories & jurisdictions worldwide. In Asia-Pacific (APAC), the top 5 countries with the highest inheritance tax (after exemptions) for EUR 10 million are South Korea 43%, Japan 21%, Thailand 3.6%, Vietnam 0.99%, Philippines 0.54% and for EUR 100 million are also South Korea 41%, Japan 26%, Thailand 4.8%, Vietnam 0.99%, Philippines 0.54%. In APAC, there are no inheritance tax for EUR 10 million & EUR 100 million in China, Hong Kong, Singapore, Australia, New Zealand, Pakistan, Oman. In Americas & Europe, the top 5 countries with the highest inheritance tax (after exemptions) for EUR 10 million are United States 40%, United Kingdom 40%, Germany 23%, Canada 22%, Croatia 14%, and for EUR 100 million, are United Kingdom 40%, United States 34%, Germany 29%, Canada 23%, Croatia 14%. In Americas, there are no inheritance tax for EUR 10 million & EUR 100 million in Mexico, Argentina, Bahamas, Bermuda. In Europe, there are no inheritance tax for EUR 10 million & EUR 100 million in Switzerland, Italy, Sweden, Poland, Romania, Slovakia, Jersey, Guernsey, Isle of Man. See below for key findings & summary | View report here
“ KPMG: 3 Highest Inheritance Tax Rates in APAC are South Korea 43%, Japan 21% & Thailand 3.6% and 3 Highest in Americas & Europe are United States 40%, United Kingdom 40% & Germany 23% “
Tom McGuiness, Global Leader, Family Business, KPMG Private Enterprise, KPMG International: “Amid rising geopolitical tension and unparalleled economic uncertainty, the leading business families that we work with are diversifying globally and putting more focus on the sustainability of their businesses, their wealth and their communities. By doing so, they can position their families for sustainable success down the generations. As a result, we are seeing more business families around the world that are focused on branching out, building up and giving back.”
KPMG Global Family Business Tax Monitor 2023 Report
KPMG, one of world’s largest audit, tax & advisory firm has released the Global Family Business Tax Monitor 2023 Report, providing key insights on family businesses around the world (Family Businesses Going Global, Family Offices & Managing Wealth, Philanthropy), tax rates & tax exemptions on family businesses by inheritance and by gifting in 57 countries, territories & jurisdictions worldwide.
Key Summary
- 3 Key Business Families Trends – Going Global, Family Offices & Managing Family Wealth, Philanthropy
- Trend 1 Going Global – Business families are globalizing, and family members are more globally mobile, assets being diversified geographically, and businesses transitioning to greener models. Tax, legal and other risks increases (jurisdictions) as business families go global. Governments are looking to tax the rich / profitable businesses as a potential source of revenue to help restore finances (COVID-19 relief).
- Trend 2 Managing Family Wealth – Management of family wealth in many countries, territories and jurisdictions, with more reliance on family offices and focus on governance. The transition often occurs as new generations are brought in to take part in the family’s business & wealth affairs. The family’s focus often turns from running the founding generation’s business to managing the family’s investments and capital for the long term. Business may also expand into new markets and industries in line with the next generation’s values.
- Trend 3 Philanthropy – Focus on transparency and environmental, social & governance (ESG) reporting (for the family business) is compelling many of them to be more public about their contributions. Change in how families are defining the purpose of wealth beyond capital in line with their values, social contributions and long-term legacies. Seeking ways to make more of an impact with their philanthropic works.
- Inheritance Tax in 57 Countries – 18 countries have inheritance tax (after exemptions) for EUR 10 million & above, 21 have inheritance tax (after exemptions) for EUR 100 million & above
- Gift Tax in 57 Countries – 17 countries have gift tax (lifetime transfers of a business) valued at EUR 10 million & above, and 19 countries have gift tax for business value at EUR 100 million & above
Tax on Business Value EUR 10 Million / $10.8 Million
- Top 5 Highest Inheritance Tax for EUR 10 Million in APAC (after exemptions) – South Korea 43%, Japan 21%, Thailand 3.6%, Vietnam 0.99%, Philippines 0.54%
- No Inheritance Tax for EUR 10 Million in APAC – China, Hong Kong, Singapore, Australia, New Zealand, Pakistan, Oman
- Top 5 Highest Inheritance Tax for EUR 10 Million in Americas & Europe (after exemptions) – United States 40%, United Kingdom 40%, Germany 23%, Canada 22%, Croatia 14%
- No Inheritance Tax for EUR 10 Million in Americas – Mexico, Argentina, Bahamas, Bermuda
- No Inheritance Tax for EUR 10 Million in Europe – Switzerland, Italy, Sweden, Poland, Romania, Slovakia, Jersey, Guernsey, Isle of Man
Tax on Business Value EUR 100 Million / $108 Million
- Top 5 Highest Inheritance Tax for EUR 100 Million in APAC (after exemptions) – South Korea 41%, Japan 26%, Thailand 4.8%, Vietnam 0.99%, Philippines 0.54%
- No Inheritance Tax for EUR 100 Million in APAC – China, Hong Kong, Singapore, Australia, New Zealand, Pakistan, Oman
- Top 5 Highest Inheritance Tax for EUR 100 Million in Americas & Europe (after exemptions) – United States 34%, United Kingdom 40%, Germany 29%, Canada 23%, Croatia 14%
- No Inheritance Tax for EUR 100 Million in Americas – Mexico, Argentina, Bahamas, Bermuda
- No Inheritance Tax for EUR 100 Million in Europe – Switzerland, Italy, Sweden, Poland, Romania, Slovakia, Jersey, Guernsey, Isle of Man
Exchange Rate ~ EURUSD: 1.08
- EUR 10 Million = $10.8 Million
- EUR 100 Milion = $108 Million
KPMG Global Family Business Tax Monitor 2023 Report
1) Family Business Tax Insights
- 57 countries, territories and jurisdictions worldwide.
- Tax relief & conditions, direct taxes (inheritances & family gifts) and indirect taxes (capital gains & stamp duties)
- Of the 57 countries surveyed, 18 have a specific inheritance tax (after exemptions) for the intra-family transmission of a family business valued at EUR 10 million. 21 have inheritance tax for businesses valued at EUR 100 million.
- 17 countries have a gift tax that applies for lifetime transfers of a business valued at EUR 10 million business. 19 countries have gift tax on transfers of EUR 100 million.
- Top 10 countries surveyed with the largest gross domestic products (GDPs), only China & Italy (2 countries) have no gift or inheritance tax that applies to the transfer of a family business. 8 countries (US, Japan, Germany, the UK, Brazil, Canada) have taxes that apply to lifetime transfers & transfers on death.
2) Key Business Families Trends
Branching Out (Going Global) – Business families are globalizing, and family members are more globally mobile, assets being diversified geographically, and businesses transitioning to greener models. Tax, legal and other risks increases (jurisdictions) as business families go global. Governments arelooking to tax the rich / profitable businesses as a potential source of revenue to help restore finances (COVID-19 relief)
Building Up (Managing Family Wealth) – Management of family wealth in many countries, territories and jurisdictions, with more reliance on family offices and focus on governance. The transition often occurs as new generations are brought in to take part in the family’s business & wealth affairs. The family’s focus often turns from running the founding generation’s business to managing the family’s investments and capital for the long term. The business may also expand into new markets and industries in line with the next generation’s values.
Giving Back (Philanthropy) – Focus on transparency and environmental, social & governance (ESG) reporting (for the family business) is compelling many of them to be more public about their contributions. Change in how families are defining the purpose of wealth beyond capital in line with their values, social contributions and long-term legacies. Seeking ways to make more of an impact with their philanthropic works.
3) KPMG on Tax Benefits for entrepreneurial families to retain wealth, to invest in profit-producing activities (broader economic benefits)
KPMG: As a fiscal policy, allowing entrepreneurial families to retain wealth so they can invest it in profit-producing activities is known to significantly stimulate job creation and innovation, leading to broader economic benefits. That’s why many of the countries provide tax support for business transfers both during lifetime and on death. The support often comes with complex restrictions on holdings and activities designed to ensure the business continues and the rules are not abused to avoid tax inappropriately. No matter where business families are located, advance planning is often needed to secure the full benefits of any tax concessions in place to facilitate the intergenerational transfers of a family businesses.
4) Tax on Family Business Transfer by Inheritance – EUR 10 Million
APAC – Tax Exemptions EUR 10 million before / after:
- South Korea – EUR 4.3 million
- Japan – EUR 2.1 million / EUR 2.1 million
- India – EUR 2.4 million / EUR 1.5k
- Thailand – EUR 364k
- Vietnam – EUR 99k / EUR 99k
- Philippines – EUR 67k / EUR 54k
- China – No Tax
- Hong Kong – No Tax
- Singapore – No Tax
- Australia – No Tax
- New Zealand – No Tax
- Pakistan – No Tax
- Oman – No Tax
America – Tax Exemptions EUR 10 million before / after:
- United States – EUR 4 million
- Canada – EUR 2.4 million / EUR 2.2 million
- Venezuela – EUR 1.25 milllion / EUR 1.25 million
- Brazil – EUR 77k / EUR 77k
- Mexico – No Tax
- Argentina – No Tax
- Bahamas – No Tax
- Bermuda – No Tax
Europe – Tax Exemptions EUR 10 million before / after:
- France – EUR 4.2 million / EUR 875k
- United Kingdom – EUR 4 million
- Netherlands – EUR 3.9 million / EUR 267k
- Spain – EUR 3.4 million / EUR 110k
- Ireland – EUR 3.1 million / EUR 219k
- Belgium – EUR 2.6 million / EUR 300k
- Germany – EUR 2.3 million
- Croatia – EUR 1.4 million
- Finland – EUR 1.2 million / EUR 339k
- Portugal – EUR 1 million
- Greece – EUR 956k / EUR 956k
- Cyprus – EUR 600,000
- Malta – EUR 500k / EUR 492k
- Austria – EUR 95k / EUR 63k
- Switzerland – No Tax
- Italy – No Tax
- Sweden – No Tax
- Poland – No Tax
- Romania – No Tax
- Slovakia – No Tax
- Jersey – No Tax
- Guernsey – No Tax
- Isle of Man – No Tax
Africa – Tax Exemptions EUR 10 million before / after:
- South Africa – EUR 3.6 million / EUR 3.5 million
- Nigeria – EUR 1.5 million / EUR 500k
- Zimbabwe – EUR 1.2k / EUR 1.2k
- Gibraltar – No Tax
- Kenya – No Tax
- Uganda – No Tax
- Tanzania – No Tax
- Rwanda – No Tax
5) Tax on Family Business Transfer by Inheritance – EUR 100 Million
APAC – Tax Exemptions EUR 100 million before / after:
- South Korea – EUR 48 million / EUR 41 million
- Japan – EUR 26 million / EUR 26 million
- India – EUR 24 million / EUR 15k
- Thailand – EUR 4.8 million
- Vietnam – EUR 999k / EUR 999k
- Philippines – EUR 675k / EUR 547k
- China – No Tax
- Hong Kong – No Tax
- Singapore – No Tax
- Australia – No Tax
- New Zealand – No Tax
- Pakistan – No Tax
- Oman – No Tax
America – Tax Exemptions EUR 100 million before / after:
- Canada – EUR 24 million / EUR 23 million
- United States – EUR 40 million / EUR 34 million
- Brazil – EUR 3.9 million / EUR 3.9 million
- Venezuela – EUR 12.5 milllion / EUR 12.5 million
- Mexico – No Tax
- Argentina – No Tax
- Bahamas – No Tax
- Bermuda – No Tax
Europe – Tax Exemptions EUR 100 million before / after:
- France – EUR 44 million / EUR 11 million
- United Kingdom – EUR 40 million
- Netherlands – EUR 39 million / EUR 3.1 million
- Germany – EUR 30 million / EUR 29 million
- Ireland – EUR 32 million / EUR 3.1 million
- Spain – EUR 36 million / EUR 1.6 million
- Belgium – EUR 26 million / EUR 3 million
- Croatia – EUR 14 million
- Finland – EUR 13 million / EUR 3.7 million
- Portugal – EUR 10 million
- Greece – EUR 9.9 million / EUR 9.9 million
- Cyprus – EUR 6 milllion
- Malta – EUR 5 million / EUR 4.9 million
- Austria – EUR 1 million / EUR 1 million
- Switzerland – No Tax
- Italy – No Tax
- Sweden – No Tax
- Poland – No Tax
- Romania – No Tax
- Slovakia – No Tax
- Isle of Man – No Tax
- Jersey – No Tax
- Guernsey – No Tax
Africa – Tax Exemptions EUR 100 million before / after:
- South Africa – EUR 37 million / EUR 37 million
- Nigeria – EUR 15 million / EUR 5 million
- Zimbabwe – EUR 12k / EUR 12k
- Gibraltar – No Tax
- Kenya – No Tax
- Uganda – No Tax
- Tanzania – No Tax
- Rwanda – No Tax
6) Key Tax Updates by Country
Asia-Pacific
Hong Kong – Tax concession for single family offices in Hong Kong (SAR) that is expected to have retrospective effect from 1 April 2022. Concession will exempt profits derived by family-owned investment holding vehicles from Hong Kong (SAR)
profits tax where the vehicle is held by a single family and managed by a single-family office (subject to conditions).
Malaysia – 2023 budget proposed stamp duty on transfer of property by way of love & affection between family members (spouses, parents and children, grandparents and grandchildren), executed from 1 January 2023 onwards, will be subject to nominal stamp duty of MYR 10, provided the recipient of the property is a Malaysian citizen. The above proposal is subject to the re-tabling of the budget, which is scheduled to occur on 24 February 2023.
South Korea – Proposed to reduce inheritance & gift taxes for family businesses.
1) Inheritance taxable value limits available for deduction would range from KRW 40 billion to KRW 100 billion ($31 million to $77 million). 2) Gift tax value limit is increased for gifted properties eligible for the low tax rates of 10% to KRW 100 billion ($77 million), and 20% for those valued at over KRW6 billion ($4.6 million). 3) Reduce follow-up period for special inheritance & gift tax benefits for family businesses to 5 years (from 7 years).
Japan – Proposal to comprehensively review the current inheritance tax system to better integrate inheritance & gift taxes. Gifts received within the 3-year period leading up to the time when an inheritance occurs should be subject to inheritance tax. With 2023 tax reform proposal, for 2024 and later years, the above 3-year look-back period will be extended to 7 years. The 2023 proposal allows taxpayers to claim annual standard deduction of JPY 1.1 million ($8,411), in addition to the maximum total deduction of JPY 25 million ($19,117) on gifts effected in 2024 and beyond when opting for the ‘settlement at the time of inheritance’ taxation system instead of the normal calendar year taxation system.
New Zealand – In 2022, to increase focus on preventing individuals from avoiding the top personal income tax rate of 39% by diverting income through lower-taxed entities. Proposals introduced during the year included amending the dividend rules so that the sale of company shares by a controlling shareholder (more than 50 percent shareholding) will be treated as a taxable dividend to the extent that the company has undistributed earnings at the time of sale. In response to concerns around the wide scope of this proposal & tight implementation timeframe, officials recommended that the changes not proceed for now. However, this reprieve is likely to be temporary.
Americas, Europe & Africa
Canada – Introduced tax relief for certain intergenerational transfers of small business corporation shares where parents or grandparents could incur a significantly higher tax bill than they would, had they sold those same shares to an arm’s-length party. New tax relief (29/6/21) – Individual taxpayer transfers shares of a qualified small business corporation to a company controlled by their children or grandchildren who are at least 18 years of age. Where the new tax relief applies, taxpayers undertaking these transfers may instead be able to realize capital gains (E.g. British Columbia, Combined federal / provincial top marginal personal tax rate is 26.75% for capital gains and 36.54% / 48.89% for dividends). Taxpayer can utilize lifetime capital gains exemption (2023 limit at CAD971,190), which is equivalent to the tax treatment that would apply if they sold the shares to an arm’s-length party.
Argentina – Considering to implement an inheritance and gift tax nationally or to ask each province to implement a provincial version of the tax.
Brazil – No inheritance & gifts taxes should apply at state level (if no complementary federal law) – 1) Donor or deceased person is domiciled outside Brazil 2) Inherited assets are located abroad 3) Probate procedure itself occurs outside Brazil.
Belgium – Certain real estate activities that go beyond mere passive management of real estate may qualify as an ‘economic activity’ – One condition that a family-owned business must meet for its shares to benefit from reduced inheritance tax rates or gift tax exemption)
Netherlands – 2023 Tax Plan to reassess business succession scheme to exclude leased real estate (no longer be taxed at the reduced tax rate). Broader evaluation of the effectiveness of the exemption, but there seems to be no inclination to abolish it altogether. Discussion of reducing the 83% exemption for gift & inheritance tax, which would increase the tax due when a family business transfers to the next generation. Outcome of this discussion will likely be included in the 2024 Tax Plan.
Spain – Proposals to eliminate differences in tax laws between Spain’s different autonomous regions (Madrid & Andalusia) in order to unify the tax treatment of inheritances throughout Spain. Proposed to legislate tax rate increases, which include raising the personal income tax rate on capital gains to 27% (from 23%).
Portugal – As of 1 January 2023, a new rule entered into force establishing that short-term gains arising from the sale of companies’ shares are subject to the progressive tax rates (up to 53% whenever the shares have been held for less than 365 days, and the taxable income of the individual is EUR 78,834 or more (the last tax bracket). Acquisition cost of securities acquired by donation that is exempt from stamp duty will corresponds to the stamp duty assessed in the 2 years before the donation.
Greece – Gift tax rules amended. Donation of any type of assets (including shares and partnership units) to persons of first-degree kinship will be taxed at 10%
of the asset’s value, with an exemption of EUR800,000.
Slovakia – In 2021, introduced an action plan for small & family businesses that sets out 10 principles for creating and improving legal and administrative environment, although no significant changes were made to the taxation of family business.
Malta – The time-limited tax incentive in terms of which a reduced rate of duty on documents and transfers of 1.5% (reduced from 2% or 5%) is applicable on the donation of company shares to qualifying family members has been extended to 31 December 2023.
Poland – The Act on Family Foundations was signed by the President (6/2/23), and will enter into force 3 months after its publication in May 2023. Proposed legislation brings such an entity into the Polish legal system and will help Polish entrepreneurs transfer their business to the next generation more effectively. The plan includes setting favorable taxation rules that will allow family foundations to claim a corporate income tax exemption for income earned by a family foundation from its activities, to the extent allowed by the Act on Family Foundations (e.g. lease, dividend, granting loans to companies in which it holds shares).
South Africa – Wealth tax is being discussed, with the 2022 Budget stating that the South African Revenue Service will focus on consolidating wealth data for taxpayers through third-party information, which would help in ‘assessing the feasibility of a wealth tax’. The High Net Wealth Unit has also been established with the aims of enhancing compliance and increasing collections from those considered high net wealth individuals.
Zimbabwe – Increased capital gains tax rates to help recover financial support provided during the pandemic.
The KPMG Global Family Business Tax Monitor 2023 Report provides key insights on family businesses around the world (Family Businesses Going Global, Family Offices & Managing Wealth, Philanthropy), tax rates & tax exemptions on family businesses by inheritance and by gifting in 57 countries, territories & jurisdictions worldwide.
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