2.4.10 The belated fee justification

States may view death taxes as a belated fee for protecting the property during the deceased’s lifetime.1 The belated fee justification overlaps the profit justification (when explained by the co-heirship theory) as both justifications look at the relationship between the state and the taxpayers. Therefore, I am of the view that the belated fee justification should not be considered a primary justification of death taxation for the same reasons as mentioned in the previous section.