Examples & Calculations Examples & Calculations

Germany–Switzerland Inheritance: Examples & Calculations

Last updated: 15 Nov 2025

Germany–Switzerland Inheritance: Examples & Calculations

Step-by-step computations for typical Germany–Switzerland estates. We show allowances, tax classes and rates, §21 ErbStG foreign-tax credits, and where family-home or business reliefs apply. Use together with our German Inheritance Tax Calculator.

Important: Germany applies a single rate to the taxable base according to the bracket in §19 ErbStG (not marginal steps). Credits under §21 are limited to the German tax attributable to the relevant foreign slice (here: Swiss assets).

Example 1 — German-domiciled decedent; child inherits Swiss portfolio + DE home

Facts: Decedent domiciled in Germany. Sole heir is an adult child (Class I). Assets at death:

  • Swiss securities portfolio: €900,000 (Swiss-situs)
  • German owner-occupied home (not used by heir post-death): €600,000
  • Estate debts / costs (lump sum chosen): €10,000
  • No prior gifts in last 10 years.
StepCalculationResult
Gross acquisition €900,000 + €600,000 €1,500,000
Less deductions (debts/costs) €1,500,000 − €10,000 €1,490,000
Less allowance (child) €1,490,000 − €400,000 €1,090,000 taxable base
Rate (Class I) €1,090,000 ⇒ bracket ≤ €6,000,000 → 19% German tax on total: €207,100

Check: €1,090,000 × 0.19 = €207,100.

§21 ErbStG credit (Swiss securities slice)

Foreign slice = Swiss portfolio €900,000. We attribute German tax proportionally to the foreign slice:

ItemCalcResult
Foreign slice proportion €900,000 / €1,500,000 60.00%
German tax attributable to foreign slice €207,100 × 60% €124,260 (credit ceiling)
Swiss inheritance tax paid on portfolio assume €100,000 equivalent €100,000
Credit allowed in Germany min(€100,000, €124,260) €100,000
German tax payable after credit €207,100 − €100,000 €107,100

If the child were to self-occupy the home for 10 years, the family-home exemption could reduce the German base further. See Example 4.

Example 2 — Swiss-domiciled decedent; spouse in Germany inherits CH home + DE brokerage

Facts: Decedent domiciled in Switzerland (canton with inheritance tax for descendants). Surviving spouse lives in Germany (Class I). Assets:

  • Swiss family home: €750,000 (Swiss-situs)
  • German brokerage account: €250,000
  • No debts; no prior gifts.
StepCalcResult
Gross acquisition€750,000 + €250,000€1,000,000
Allowance (spouse)€1,000,000 − €500,000€500,000 taxable base
Rate (Class I)€500,000 ⇒ bracket ≤ €600,000 → 15%German tax on total: €75,000

Check: €500,000 × 0.15 = €75,000.

§21 credit on Swiss home slice

ItemCalcResult
Foreign slice proportion€750,000 / €1,000,00075.00%
German tax attributable to Swiss slice€75,000 × 75%€56,250
Swiss inheritance tax paid on the houseassume €40,000€40,000
Credit allowedmin(€40,000, €56,250)€40,000
German tax payable€75,000 − €40,000€35,000

Example 3 — Business shares with §13a/13b relief and §21 credit on Swiss securities

Facts: Child (Class I) inherits:

  • Shares in a qualifying German family company: €1,600,000 (eligible for 85% relief)
  • Swiss securities portfolio: €400,000
  • No debts; no prior gifts.
StepCalcResult
Gross acquisition€1,600,000 + €400,000€2,000,000
Apply business relief (85%)€1,600,000 × 15% taxable€240,000 taxable portion
Adjusted gross for ErbSt€240,000 (business taxable part) + €400,000 (Swiss)€640,000
Allowance (child)€640,000 − €400,000€240,000 taxable base
Rate (Class I)€240,000 ⇒ bracket ≤ €300,000 → 11%German tax on total: €26,400

Check: €240,000 × 0.11 = €26,400.

§21 credit for Swiss securities slice

ItemCalcResult
Foreign slice proportion (by gross before allowance)€400,000 / €2,000,00020.00%
German tax attributable to Swiss slice€26,400 × 20%€5,280
Swiss inheritance tax on those securitiesassume €10,000€10,000
Credit allowedmin(€10,000, €5,280)€5,280
German tax payable€26,400 − €5,280€21,120

If the 100% option relief were available and conditions met, the company portion could be fully exempt—re-run with our calculator.

Example 4 — Family-home exemption for child (200 m² cap)

Facts: Child inherits German family home (living space 220 m², value €800,000) and commits to own use for ≥10 years. No other assets, no debts.

StepCalcResult
Tax-free portion200 m² / 220 m² × €800,000≈ €727,273 exempt
Taxable residue€800,000 − €727,273≈ €72,727
Allowance (child)€72,727 − €400,000Residual €0 → no German tax

If self-use stops within the holding period, the exemption may be clawed back. Plan occupancy and fallbacks.

Computation tips & quick formulas

  • German taxable base = (Gross assets after specific reliefs) − (personal allowance) − (deductions).
  • Rate = single rate from the class I/II/III table for the entire taxable base (not marginal).
  • German tax attributable to foreign slice (proxy) = (Total German tax) × (Foreign gross slice ÷ Total gross). Document your method in the §21 memo.
  • Credit allowed = min(Foreign death tax paid on the slice, German tax attributable to that slice).
  • Keep a bridge memo from Swiss market value → German values (BewG, reliefs) for each asset.

Next steps & templates

Run your numbers

Use our calculator for allowances and rate bands. Then build a §21 worksheet per country and, if needed, per canton.

Templates & services

Get the editable credit worksheets, reconciliation memo, and bilingual checklists.

Also see: Real estate & business · Executor · Trusts & foundations