Appenzell Innerrhoden Inheritance Tax Nonresident Guide
Last updated: 12 Nov 2025
Appenzell Innerrhoden Inheritance Tax — Nonresident Guide
How nonresidents are exposed to Appenzell Innerrhoden (AI) inheritance tax: what counts as AI-situs, common apportionment methods, what documents to provide, and how to avoid overreach. Swiss service delivered by Sesch TaxRep GmbH, Buchs SG.
What counts as AI-situs for nonresidents
| Asset type | Typical AI treatment for nonresidents | Notes |
|---|---|---|
| Real property located in Appenzell Innerrhoden | In scope | Title extract (Grundbuch) and valuation/appraisal required. |
| Tangible personal property normally kept in AI | In scope | Furniture, equipment, vehicles kept/stored in AI; prove location. |
| Movables circulating across cantons | Partially in scope | Allocate by storage/use logs; keep delivery notes and addresses. |
| Pure intangibles (bank a/c, listed shares) of a nonresident | Generally out of scope | Unless a business situs exists tying them to AI. |
| Operating business assets with AI nexus | In scope to the AI slice | Allocate based on people/assets/contracts located in AI. |
| Art on loan to qualifying Swiss charities/museums | Often out of AI | Check loan agreements and the institution’s status. |
Key principle: for nonresidents, AI focuses on AI-situs real property and tangibles; most intangibles follow the decedent’s domicile absent a business situs.
Apportionment models (how the fraction is used)
- Mode A — Situs-only progression: The rate is determined on the AI-situs amount only. Simple when only a house or limited tangibles are in AI.
- Mode B — Worldwide × AI fraction: A progression rate may be determined on a broader base and multiplied by an AI fraction (AI-situs numerator ÷ worldwide denominator). Ensure the denominator includes only items required by local rules.
Practice may vary by case complexity. Prepare evidence to support both computations.
Common nonresident scenarios
Typically only the AI home is taxed. Provide valuation and foreign account statements showing non-AI situs.
Allocate value by storage/use; AI taxes the portion kept/used in AI. Keep logs and addresses.
Exemption may not apply; expect taxable scales. Consider structuring to mitigate bracket effects.
Qualifying gifts reduce progression; attach recognition letters and statutes.
Documentation & evidence checklist
- Death certificate; will/certificate of heirs.
- Land-registry extract and appraisal for AI real estate.
- Inventory of tangibles with storage addresses in AI vs. outside.
- Bank/brokerage statements proving non-AI location of intangibles.
- Relationship proofs (marriage/registered partnership; lineal descent).
- Invoices for debts & administration costs.
- Charity confirmations (recognition letter; foundation statutes).
- If business nexus: people/assets/contracts matrix by canton.
Worked examples
| Facts | Computation (illustrative) | Practice note |
|---|---|---|
| Nonresident; AI chalet CHF 900k; foreign securities CHF 1.6m; heir is sibling. | Mode A: rate on CHF 900k; Mode B: rate on CHF 2.5m × (900/2,500). Taxes limited to AI slice. | Provide appraisal + foreign statements; avoid including foreign intangibles in numerator. |
| Nonresident; equipment stored 60% in AI, 40% in SG; niece as heir. | Allocate equipment value 60% to AI; apply niece scale to that portion. | Keep storage logs, delivery notes, photos, insurance addresses. |
| Nonresident; AI flat CHF 650k bequeathed to registered partner. | Apply partner relief/exemption per local rules; potential zero tax. | Submit registered partnership proof with the return. |
Filing mechanics for nonresidents
FAQs
Do nonresidents pay on bank accounts held in AI?
Typically no for pure intangibles without a business situs. AI focuses on real estate and tangibles situated in AI for nonresidents.
How is mixed-canton tangible property handled?
Allocate by storage/use; AI taxes only the portion attributed to AI. Provide objective logs and addresses.
Is a worldwide calculation always required?
Not always. Some cases use situs-only progression; others determine a rate on a broader base and apply an AI fraction. Prepare evidence for either method.