Appenzell Rhodes-Extérieures Cas de l'impôt sur les successions
Dernière mise à jour : 12 Nov 2025
Appenzell Ausserrhoden Inheritance Tax — Cases & Examples
A practical digest of Appenzell Ausserrhoden inheritance tax issues seen in rulings and administrative practice: situs 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 AR practice
AR taxes AR-situs real estate and tangibles for nonresidents; most intangibles follow domicile unless a business situs. Mixed-canton movements (equipment, funds) need allocation logs.
Spouse/registered partner and often direct descendants benefit from relief/exemption; partners vs. registered partners treated differently. Beneficiary class proofs can alter the base significantly.
When assets span multiple cantons, AR limits its tax to the AR-slice. Prevent double counting with a clear location/value matrix and supporting documentation.
Date-of-death values and appraisal methods (especially for real estate and special assets) drive assessments; late or weak evidence often leads to upward adjustments.
Case digests (high level)
| Thème | What was at issue? | Outcome (summary) | Note de pratique |
|---|---|---|---|
| Nonresident holiday home in AR | Decedent domiciled abroad with AR property and foreign bank assets. | Tax limited to the AR property; foreign bank assets excluded absent nexus. | Provide Grundbuch, appraisal, and foreign account statements. |
| Unregistered partner claim | Claim for spousal-equivalent relief denied. | Partner taxed as non-exempt class. | Ensure partnership is legally registered or structure differently. |
| Movables across cantons | Furniture and equipment stored/use across AR and SG. | Pro rata allocation based on documented addresses; AR taxed its portion only. | Keep delivery logs, insurance schedules, storage receipts. |
| Charitable bequest | Charity qualification issue and timing of gift. | Gift exempt when charity status proved; delayed documentation led to partial taxable base. | Attach recognised charity letter and meet deadlines. |
| Valuation date dispute | Estate assets increased materially after death. | Date‐of‐death value accepted when properly documented; late valuations discounted. | Commission appraisal close to date of death. |
Worked hypotheticals
AR estate: flat CHF 900k; foreign securities CHF 1.7m. Heir: sibling.
- Situs : Only the AR flat is taxed.
- Progression : Either situs-only or worldwide × (AR/Worldwide) fraction.
- Advice: Provide appraisal + foreign statements to support non-taxable part.
Assets: AR house CHF 600k, ZH warehouse CHF 900k, movable assets split; heirs include partner + niece.
- Allocation : AR taxed AR-slice; ZH separately; avoid double taxation.
- Exemptions : Registered partner relief; niece taxed.
- Conseil : Maintain canton-by-canton location matrix.
Research pointers & sources
- AR tax administration’s “Erbschafts- und Schenkungssteuer” pages (overview, forms, contacts).
- Swiss Civil Code (succession & Pflichtteile) for exemption context.
- Inter-cantonal comparative practice notes on situs/apportionment.
- Swiss jurisprudence databases for rulings on heir class, valuation, and cross-canton allocation.
For briefs, keep PDFs of notices, appraisals, inventories, correspondence.
FAQ
Are nonresident bank accounts in AR taxed?
Typically not—pure intangibles follow domicile unless tied into a business situs. AR focuses on AR real/tangible property for nonresidents.
How treat partners vs. registered partners?
Registered partners often align with spousal relief; non-registered may face taxable scales unless specific relief applies.
Can valuation be challenged?
Yes—file an objection within the time on the assessment and attach independent appraisal/market evidence.