Last updated: 15 Nov 2025

Germany–Switzerland Inheritance: Executor & Estate Administration

Practical playbook for executors and administrators handling Germany–Switzerland estates: Erbschein, EU Certificate of Succession, Swiss inheritance certificates, bank/KYC, asset transfers, valuations, and building an audit-ready evidence pack for §21 ErbStG credits and treaty relief.

1) Establishing authority: Erbschein, EU Certificate & Swiss inheritance certificate

• Germany: Use a notarial will + opening record or apply for a certificate of inheritance (Erbschein). For intra-EU estates (where EU assets exist), the EU Certificate of Succession can evidence status across Member States (except DK/IE).
• Switzerland: Obtain an official inheritance certificate (Erbbescheinigung or cantonal equivalent) from the competent court/notary/authority, often based on an inventory and heir declarations. Requirements vary by canton.
• Powers of Attorney: Post-death powers typically lapse; banks in both countries usually require court/registry evidence (no “private POA only”).
• Cross-recognition: Not automatic between Germany and Switzerland. Plan translations, apostilles/legalisations, and, if needed, local counsel for filings and recordings (land registers, company registers, banks).

2) Inventory, valuations & reconciliations

• Death-date inventory per jurisdiction; identify situs under the Germany–Switzerland inheritance tax treaty and domestic rules (German vs. Swiss real estate, bank accounts, participations, movable assets).
• Valuations:
  • Germany: values per BewG for real estate; simplified earnings/expert opinion for businesses.
  • Switzerland: market value appraisals per cantonal practice for real estate and closely held companies; tax values where accepted by the canton.
• Reconciliation memo: Bridge Swiss market values → German taxable values asset-by-asset to preempt queries and facilitate §21 computations.
• Debt & encumbrances: Document deductibility and allocation (mortgages, business loans, pledges, usufruct/life interests) in both systems.

3) Banks, brokers & KYC: what they expect

• Authority pack: Erbschein and/or EU Certificate, Swiss inheritance certificate or comparable order; certified/apostilled + sworn translations where required by German or Swiss banks.
• KYC/AML: Executor IDs, proof of address, tax numbers for the estate; CRS/FATCA declarations where relevant; source-of-funds explanations for large transfers.
• Blocking & release: Expect temporary blocks on accounts and safe-deposit boxes; provide authority documents, inheritance certificate details and clear distribution instructions.
• Dividends/interest post-death: Track as estate income vs. capital; keep FX records for cross-currency distributions between DE and CH.

4) Asset transfers: real estate, company shares, accounts

• Real estate (DE): Land registry update based on will+opening record or Erbschein; ensure continuity of insurance, utilities and property tax registration.
• Real estate (CH): Registration at the competent land registry (Grundbuchamt) in the canton; coordinate notary, transfer taxes/fees and any municipal requirements.
• Company shares: GmbH share list update / commercial register filings (Germany); Swiss AG/GmbH share register updates and any commercial register notifications in Switzerland.
• Brokerage/bank: Estate account setup; transfers to heirs; FX conversions documented with rates and bank statements; closure of legacy accounts once distributions are complete.

5) Tax filings & §21 credit evidence

• Germany (ErbSt): Per-beneficiary inheritance tax returns (allowances, classes, exemptions, §§13a/13b relief). Attach valuation evidence and detailed situs allocation schedules.
• Switzerland: Cantonal (and, where applicable, communal) inheritance/gift tax returns, typically in the canton of last residence and in cantons where real estate is located.
• §21 ErbStG credit pack: Swiss assessments, proof of payment, asset-by-asset mapping to the Swiss “foreign slice”, and German tax attributable to that slice (credit = lower of Swiss tax paid or German tax on the same slice).
• Treaty angle: Apply domicile tie-breakers and situs allocation under the Germany–Switzerland inheritance tax treaty; document conclusions in a short memo to minimise audit friction.

6) Timeline management & interest risk

Mitigate interest by planning Swiss tax payments early so that German assessments can factor in §21 credits, and by submitting a complete, bilingual evidence pack.

7) Checklists, templates & data room

• Data room: Access-controlled; bilingual index (DE/EN); versioning and audit trail visible for tax authorities if needed.
• Naming convention: YYYY-MM-DD_country-canton_asset_doc-type.pdf (e.g. 2025-03-01_CH-ZH_Immobilie_Gutachten.pdf).
• Checklists: Use our bilingual lists for authority docs, valuation exhibits, Swiss tax assessments and §21 mapping.
• Translations: Sworn/certified where authorities require; keep originals and certified copies together in the data room.

Download: Checklists & documents

Next steps & services

Also see: Planning · Trusts & foundations