Thurgau Inheritance Tax Cases
Last updated: 12 Nov 2025
Thurgau Inheritance Tax — Cases & Examples
A practical digest of Thurgau inheritance tax issues seen in rulings and administrative practice: situs classification for nonresidents, exemptions by heir class, apportionment across cantons, valuation disputes, and procedural timing. Swiss service delivered by Sesch TaxRep GmbH, Buchs SG.
Key topics in Thurgau practice
Real estate and tangibles in Thurgau are within scope; pure intangibles of nonresidents are generally out unless a business situs exists. Watch mixed situations (company assets stored/used in Thurgau).
Spouse/registered partner and often direct descendants: exempt. Evidence quality (relationship proofs) can decide outcomes; partners vs. registered partners matters.
When multiple cantons are involved, allocation follows situs with documentation. Double counting is curbed by fractions and inter-cantonal coordination.
Assessment hinges on proper valuation dates and methods (real estate appraisals; specialised assets like art/collections/equipment).
Case digests (high level)
| Theme | What was at issue? | Outcome (summary) | Practice note |
|---|---|---|---|
| Nonresident condo (TG) | Whether only the Thurgau apartment is taxable when the decedent is domiciled abroad. | Tax limited to the TG property; foreign intangibles ignored absent business situs. | Provide title extract, appraisal, and proof that accounts/securities were outside TG. |
| Unregistered partner | Exemption claim for cohabiting partner vs. registered partnership. | Exemption denied; applied progressive partner/“unrelated” scale per local rules. | Clarify relationship status; consider testamentary structuring and documented support. |
| Cross-canton machinery | Allocation of movable equipment used across cantons. | Allocated pro rata by location/usage logs; TG taxed the portion stored/used in TG. | Keep storage addresses, delivery notes, and usage logs to support fractions. |
| Charitable legacy | Whether a foundation qualified for exemption. | Exempt where recognition met and documents complete. | Attach recognition letter and purpose statutes; consider percentage caps. |
| Valuation date | Dispute over market drop between death and assessment. | Accepted a date-of-death appraisal with adjustment corridor. | Commission neutral appraisals near death date; document later changes. |
Worked hypotheticals
Assets: TG house CHF 1.1m; foreign securities CHF 1.9m. Heir: sibling.
- Situs: Only CHF 1.1m TG house in scope.
- Rate: Apply sibling progression; if “worldwide × fraction” used, rate on CHF 3.0m × (1.1/3.0).
- Docs: Appraisal, land-registry extract, brokerage statements proving foreign situs.
Assets: TG apartment CHF 600k, ZH warehouse CHF 800k, movables split. Multiple heirs incl. partner and nephew.
- Allocation: TG assesses TG-situs slice; ZH separately; avoid overlap via evidence.
- Exemptions: Partner status determines relief; nephew taxed progressively.
- Practice: Keep a canton-by-canton location matrix.
Research pointers & sources
- Thurgau tax administration pages on Erbschafts- und Schenkungssteuer (guidance, forms, contact).
- Swiss Civil Code provisions on succession and forced shares (context for structuring).
- Inter-cantonal allocation practice notes and any local circulars on situs/progression.
- Swiss case law databases for comparable rulings on heir class exemptions and valuations.
For citations in briefs, keep PDFs of notices, appraisals, inventories, and correspondence.
FAQs
Do nonresidents pay on Thurgau bank accounts?
Typically no for pure intangibles without business nexus; the focus is Thurgau real/tangible property.
How are partners treated?
Registered partners typically align with spouse relief; unregistered partners may face taxable scales unless specific relief applies.
Can we appeal the valuation?
Yes—within the objection period stated in the assessment. Provide independent appraisals and market evidence.