Last updated: 15 Nov 2025
Germany–Switzerland Inheritance Tax – Coordination & §21 Credits
From valuation evidence to foreign tax proofs: this page outlines the end-to-end workflow to coordinate Germany–Switzerland filings, compute § 21 ErbStG credits, synchronize timelines between Germany and the Swiss cantons, and prepare audit-ready documentation.
Who does what? Treaty allocation, §21 computation, and cross-border timelines are coordinated here.
National and cantonal filings are handled by our teams:
🇩🇪 German Inheritance Tax Service ·
🇨🇭 Swiss Inheritance Tax Service.
Contents
1) Filing workflow at a glance
| Phase | Germany (ErbStG) | Switzerland (cantons) | Notes |
|---|---|---|---|
| Scoping | Residency, scope (worldwide vs. German-situs), heirs per person | Domicile in Switzerland, canton of last residence, assets per canton (immovable vs. movable) | Align on treaty/tie-breakers; identify relevant cantons and any municipal taxes |
| Valuation | BewG methods (real estate), simplified earnings / expert report (business) | Market value at date of death per cantonal practice; local real estate and business valuation standards | Keep reconciliations; one evidence set across both sides where possible |
| Documentation | Heir acquisition breakdown, debts, allowances, exemptions, §§13a/13b exhibits | Inventories, inheritance tax/gift tax returns (where applicable), supporting exhibits | Translations/Notarization where required; map each document to both tax bases |
| §21 credit | Compute German tax attributable to foreign (Swiss) assets per country/canton | Provide cantonal assessments & proof of payment for inheritance/gift taxes | Credit = lower of Swiss tax or German tax on the corresponding Swiss slice |
| Submission | File with Finanzamt; respond to queries and provide §21 evidence pack | File with cantonal tax offices; obtain assessments and payment confirmations | Sync sequences to avoid timing gaps and double cash strain |
2) Valuations (BewG vs. Swiss market value) & evidence
- Real estate (DE): statutory valuation per BewG/ImmoWert inputs; distinction between owner-occupied and rented property.
- Real estate (CH): market value appraisals according to cantonal rules (capitalized earnings methods, comparative value, or tax-value-based approaches).
- Business interests: simplified earnings method / expert report in Germany (e.g., IDW S 1); coordinate with Swiss practice for valuation of participations and owner-managed companies.
- Securities and cash: date-of-death statements; FX conversions (EUR/CHF); harmonized pricing sources.
- One evidence set: maintain a joint valuation memo; reconcile German taxable values to Swiss market values for key assets (real estate, business, large portfolios).
Deep dive: Real estate & business assets
3) Swiss tax proof & payments
- Collect cantonal and communal assessments for inheritance/gift taxes (per canton) and any explanatory rulings.
- Secure official proof of payment (tax office confirmations, payment slips, bank statements) for amounts that should be credited under §21 ErbStG.
- Document situs and allocation per asset (which canton, movable vs. immovable, direct vs. indirect holdings).
- Track exemptions and reductions used in Switzerland (e.g. spouse/descendant relief) so that the German credit matches the actual foreign taxable base.
4) §21 ErbStG credit computation (step-by-step)
- Compute German base per beneficiary (after allowances, deductions, exemptions, and any business relief under §§13a/13b).
- Isolate Swiss assets by country and, where useful, by canton; determine the German tax attributable to those foreign slices.
- Collect Swiss inheritance/gift tax actually paid on the same slices (cantonal and, where applicable, communal). Ensure comparability (only death/gift taxes count).
- Apply credit rule: for each Swiss slice, credit the lower of (a) Swiss tax paid or (b) German tax attributable to that slice under §21 ErbStG.
- Compile evidence pack: assessments, payment proofs, valuation reports, situs memo, allocation schedules and calculation worksheets.
Concepts are aligned with the general §21 explanation in the German inheritance tax guide (foreign citizens & double taxation section).
5) Swiss cantonal filings (coordination)
- Identify relevant cantons: last domicile of the decedent and cantons where Swiss real estate is located.
- Prepare inventories: per canton, separating assets taxable there (typically immovable property and, depending on canton, movable assets linked to domicile).
- File inheritance/gift tax returns: per canton/municipality, using aligned valuations and beneficiary breakdowns.
- Sync with Germany: align filing windows and payment dates so that German §21 credits can be claimed promptly after Swiss tax is assessed and paid.
6) Timelines & interest risk
Germany – typical sequence
- Notification to Finanzamt & data collection
- Valuation evidence compiled (BewG, business valuations)
- German inheritance tax returns & provisional §21 computation
- Assessment, queries, and final credit confirmation after Swiss proofs are available
Switzerland – typical sequence
- Issuance of inheritance certificate and inventories
- Submission of cantonal inheritance/gift tax returns
- Assessment & payment of cantonal/communal taxes
- Issue official payment confirmations for German credit purposes
Mitigate interest by planning Swiss payments early enough so that German assessments can immediately factor in §21 credits.
7) Data room & translation standards
- Set up a shared, access-controlled data room with clear index, versioning, and audit trail.
- Use bilingual folder labels and, for key documents (assessments, court decisions, valuations), provide certified translations where required by the Finanzamt.
- Name files consistently (e.g.
YYYY-MM-DD_country-canton_asset_doc-type.pdf) to support allocation, timeline proof, and slice-based §21 calculations.
Next steps & resources
Start coordination
We manage German and Swiss inheritance tax filings and the cross-border credit process from one desk.
Related: Planning · Executor & administration · FAQ