Holding. For a decedent domiciled abroad, St. Gallen taxes SG-situs real estate (apartment/chalet) at date-of-death market value; foreign intangibles remained out of scope.

Reasoning. Situs follows immovable property location; intangibles follow domicile unless functionally tied to a SG permanent establishment.

Practice point. Attach land-register extract and independent appraisal; keep FX and methodology consistent with foreign filings.

Holding. Spouse/registered partner and direct descendants benefitted from statutory relief; unrelated beneficiaries taxed on their shares at progressive rates.

Reasoning. Rate classes determined by relationship; exemption/relief is applied before communal modifiers.

Practice point. Split bequests to favoured classes where appropriate and document civil status to substantiate relief.

Holding. Only debts allocable to SG-situs property (e.g., property mortgage) reduced the SG base; general estate liabilities were excluded.

Reasoning. Functional nexus required between liability and SG asset; prevents double deduction inter-cantonally.

Practice point. Provide lender statements as of date of death; show direct linkage to the SG parcel.

Holding. Substantial lifetime gifts made shortly before death were considered in assessing beneficiary burden; anti-avoidance rationale applied.

Reasoning. Prevents circumvention of class-based burdens; timing and intent reviewed.

Practice point. Document gift dates/values; expect queries if material transfers occurred within the look-back window.

Holding. A defensible minority/illiquidity discount was accepted for a non-listed shareholding based on an independent expert report.

Reasoning. Fair market value standard at date of death; discount justified by lack of control/marketability.

Practice point. Commission a valuation report aligned with Swiss practice; reconcile to foreign estate values to avoid mismatches.

Holding. Where probate proceeded abroad, a limited SG return covering only SG-situs assets was sufficient; foreign assessments served as context for credits.

Reasoning. Inter-cantonal/foreign coordination to prevent double taxation; SG jurisdiction tied to situs assets.

Practice point. Include foreign assessment letters and payment proofs when claiming relief.