Appenzell Innerrhoden Inheritance Tax Cases
Last updated: 12 Nov 2025
Appenzell Innerrhoden Inheritance Tax — Cases & Examples
A practical digest of Appenzell Innerrhoden 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 AI practice
AI taxes AI-situs real estate and tangibles for nonresidents; most intangibles follow domicile unless there is a business situs. Mixed situations (equipment stored/used in multiple cantons) need allocation evidence.
Spouse/registered partner and often direct descendants benefit from relief/exemption; partners vs. registered partners are treated differently—proof of status is outcome-determinative.
Where assets sit in several cantons, AI limits its tax to the AI-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)
| Theme | What was at issue? | Outcome (summary) | Practice note |
|---|---|---|---|
| Nonresident chalet (AI) | Scope of taxation when the decedent was domiciled abroad with an AI property. | Tax limited to the AI real estate; foreign intangibles excluded without business nexus. | Provide Grundbuch extract, appraisal, and foreign statements proving non-AI situs. |
| Unregistered partner | Claim of spousal-equivalent exemption. | Denied; applied taxable scale for non-registered partners. | Confirm relationship status or re-structure bequests to exempt classes. |
| Cross-canton machinery | Movables stored/used across AI and SG. | Allocated pro rata based on storage/use logs; AI taxed the AI share only. | Keep storage addresses, delivery notes, insurance schedules. |
| Charitable bequest | Qualification of a foundation for exemption. | Exempt when recognition and purpose statutes were provided. | Attach recognition letters; mind percentage/conditions in the will. |
| Valuation date dispute | Market movement between death and assessment. | Accepted date-of-death appraisal with limited corridor. | Commission neutral valuations close to the death date; document later changes. |
Worked hypotheticals
Assets: AI flat CHF 850k; foreign securities CHF 1.7m. Heir: sibling.
- Situs: Only the AI flat is in scope.
- Progression: Either situs-only or worldwide × (AI/Worldwide) fraction.
- Docs: Appraisal, Grundbuch extract, brokerage statements.
Assets: AI home CHF 600k, ZH warehouse CHF 900k, movables split; heirs include partner and niece.
- Allocation: AI assesses AI-slice; ZH separately; avoid double counting.
- Exemptions: Registered partner relief vs. niece progressive scale.
- Practice: Prepare a canton-by-canton location matrix.
Research pointers & sources
- Appenzell Innerrhoden tax administration pages for Erbschafts- und Schenkungssteuer (overview, forms, contacts).
- Swiss Civil Code (succession & Pflichtteile) for planning context.
- Inter-cantonal allocation practice notes; any local circulars on situs and progression.
- Swiss case-law databases for comparable rulings on heir class and valuation issues.
For briefs, maintain PDFs of notices, appraisals, inventories, and correspondence as citations.
FAQs
Do nonresidents pay on AI bank accounts?
Typically no for pure intangibles without business nexus; AI focuses on AI real/tangible property for nonresidents.
How are partners treated?
Registered partners usually align with spousal relief; non-registered partners may face taxable scales unless specific relief applies.
Can valuation be appealed?
Yes—file an objection within the period on the assessment and include independent appraisals and market evidence.