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Ultimo aggiornamento: 12 Nov 2025
Aargau Inheritance Tax — Case Notes & Examples
Practical case patterns for the Canton of Aargau’s inheritance tax (Erbschaftssteuer): situs outcomes for nonresidents, relationship-based exemptions, valuation disputes, and inter-cantonal/cross-border allocation.
Situs & Nonresident Cases
- Real estate in Aargau (nonresident decedent). Aargau asserts taxing rights over immovable property situated in the canton; intangibles generally follow the decedent’s domicile and fall outside Aargau for nonresidents.
- Tangible movables stored in Aargau. Long-term storage or habitual location in Aargau can create situs for high-value art, vehicles or collections.
- Business presence. Assets tied to a fixed facility in Aargau may be partly allocable to Aargau even when the owner is domiciled elsewhere.
Exemptions by Relationship
As a general pattern across German-speaking cantons, spouses and descendants are commonly exempt or strongly favored; transfers to more remote relatives or unrelated beneficiaries are taxed at progressive scales. Always confirm current Aargau brackets before relying on an exemption.
Valuation & Evidence Disputes
Real estate appraisals
Disagreements often turn on market method vs. income method for rentals, treatment of renovations, and vacancy/tenancy discounts.
Private company shares
Key issues include minority/marketability discounts, normalisation of earnings, and comparable-selection for multiples.
Robust third-party valuations and transparent working papers reduce the risk of reassessment and interest.
Inter-Cantonal & Cross-Border Allocation
- Between cantons. Domicile vs. situs allocation prevents double taxation: Aargau taxes Aargau-situs assets (notably real estate); the domicile canton taxes remaining assets subject to its rules.
- With foreign countries. If the decedent was domiciled abroad, Aargau taxes Aargau assets while the home country may tax worldwide assets; credits/relief depend on foreign law and timing.
Esempi di lavoro
| Scenario | Outcome |
|---|---|
| Nonresident with Baden rental and securities abroad. | Aargau taxes the Baden property; securities typically outside Aargau scope. Coordinate foreign credits to avoid double taxation. |
| Zurich resident inherits Aargau lakeside house. | Inter-cantonal allocation: Aargau taxes the Aargau real estate; Zurich applies its rules to domicile-situs assets. |
| Art on long-term loan stored at an Aargau residence. | May be treated as tangible movable property situated in Aargau; fact-specific analysis required. |
| Holding company owning Aargau real estate. | Shares are intangibles (follow domicile) but look-through, valuation, and transfer-tax issues can arise; structure-specific advice is essential. |
Practice Pointers
- Document domicile and the physical location of movables to support situs positions.
- Prepare early valuations; reconcile to registry/notarial records for real estate.
- Align inter-cantonal and foreign filings to preserve credits and avoid timing gaps.
- Seek a closing/clearance letter from Aargau before property transfers or distributions.
Need a second opinion or appeal support? Engage via the green service link above (Sesch TaxRep GmbH, Buchs SG).
Domande frequenti
Does Aargau tax nonresidents on bank accounts?
Generally no—intangibles follow domicile for nonresidents; real estate and certain tangibles in Aargau are the usual triggers.
Can I challenge an appraisal used by the tax office?
Yes. Provide an independent valuation and evidence; observe objection/appeal deadlines stated in the assessment.
Do exemptions for spouses/descendants remove the need to file?
No. Filings typically proceed so the authority can verify exemptions and issue clearance.
Who handles filings and appeals?
Our Swiss engagements are delivered by Sesch TaxRep GmbH, Buchs SG. See the service link above for fixed-fee options.
