Page "Tax treaty" Paragraph 19

Generally, income taxes and inheritance taxes are addressed in separate treaties.

Inheritance tax treaties often cover estate and gift taxes.

Generally fiscal domicile under such treaties is defined by reference to domicile as opposed to tax residence.

Such treaties specify what persons and property are subject to tax by each country upon transfer of the property by inheritance or gift.

Some treaties specify which party bears the burden of such tax, but often such determination relies on local law ( which may differ from country to country ).