Geneva Inheritance Tax Planning
Last updated: 26 Oct 2025 • Author: Alexander Foelsche CPA (US), WP (DE), RE (CH)
Geneva Inheritance Tax — Planning Guide
Practical strategies to reduce, defer, and fund Geneva inheritance tax under cantonal rules. Coordinate heir-class exemptions, matrimonial & succession tools, situs management for nonresidents, valuation & documentation, and liquidity for timely payment after assessment by the Administration fiscale cantonale (AFC).
Top planning moves (at a glance)
Design bequests & contracts
- Spousal/partner relief: Use exemptions for spouse/registered partner where applicable; coordinate with the matrimonial property regime.
- Will & inheritance contract (Erbvertrag): Define remainders (Vorerbene/Nacherbene), usufructs, and provide disclaimer options to adapt post-mortem.
- Charitable components: Outright gifts or foundations to reduce the taxable base for non-exempt heirs.
Manage situs & valuation
- Nonresidents: Limit Geneva-situs assets where feasible; keep intangibles from acquiring a Geneva business situs.
- Appraisals: Obtain Geneva-qualified valuations for real estate and significant tangibles at date of death.
- Deductions: Prepare invoices, contracts, and authority/court approvals (where relevant) to substantiate debts and expenses.
Common structures
| Tool | Primary goal | Practice notes |
|---|---|---|
| Matrimonial property agreement | Allocate assets between spouses/partners pre-succession | Select regime consistent with family and tax goals; align titles and beneficiary designations. |
| Will / inheritance contract (Erbvertrag) | Control dispositions; provide flexibility | Consider Vorerbene/Nacherbene, usufructs, specific legacies; add disclaimer language. |
| Usufruct to spouse/partner | Provide income/use while steering remainder | Value the usufruct per cantonal practice; specify maintenance and insurance obligations. |
| Charitable bequests/foundations | Reduce taxable base | Confirm qualifying status; keep governing documents and valuation reports. |
| Lifetime gifts | Shift future growth out of the estate | Document transfers; review Geneva/Swiss rules on inter vivos transfers, notifications, and any add-backs. |
| Life insurance liquidity | Fund tax and equalize shares | Coordinate policy ownership/beneficiaries so proceeds are available for the assessment due date. |
Nonresident & cross-border planning
- Asset location: Prefer non-Geneva intangibles for nonresident decedents; if holding Geneva property, plan who receives it and how related debts affect the Geneva base.
- Business situs: Keep management, books, and decision-making for financial assets outside Geneva to avoid a Geneva business-situs argument.
- Ancillary steps: Line up appraisals, land-registry extracts, and documentation early for a filing limited to Geneva assets.
See the Nonresident Guide for definitions, examples, and a filing checklist.
Valuation, deductions & documentation
Valuation playbook
- Engage Geneva-qualified appraisers for real estate and significant tangibles as of the valuation date.
- Reconcile foreign/federal estate valuations with Geneva filings to avoid mismatches.
- Document market conditions and methodology in reports and workpapers.
Deductions & proof
- Maintain invoices, agreements, and proof of payment for administration expenses.
- Substantiate liabilities (mortgages/loans) tied to Geneva assets; allocate deductions proportionally for nonresidents.
- Keep relationship proofs (family register extracts) to support exemptions by heir class.
Liquidity & timing
Cash for assessment
- Project tax exposure and arrange liquid funds or insurance proceeds to meet the assessment due date (often ~30 days).
- Coordinate sales/closings to provide cash before interest on arrears applies.
Payment plans & clearances
- Discuss payment arrangements with the AFC early if liquidity is tight; provide cash-flow documentation.
- Plan for a tax clearance certificate post-assessment to satisfy land-registry and banking requirements.
Suggested planning workflow
- Inventory & map Geneva-situs vs. non-Geneva assets; list heirs/beneficiaries and exemptions.
- Model scenarios with the Geneva calculator; test marital/charitable/lifetime-gift options.
- Draft documents (will, inheritance contract, beneficiary designations, disclaimers) reflecting situs and liquidity objectives.
- Assemble proof (appraisals, invoices, liability statements, relationship documents) to support deductions and exemptions.
- Execution & review: retitle assets where needed, update designations, and schedule reviews for life events and law changes.
FAQs
Does a living trust avoid Geneva inheritance tax?
No. It may streamline administration, but the cantonal inheritance tax depends on the taxable transfer and heir class, not on probate status.
Can charitable/spousal relief eliminate tax?
Often, yes for qualifying beneficiaries. Confirm heir-class exemptions and ensure documentation and valuations support the claimed relief.
What’s the simplest way to lower Geneva exposure for nonresidents?
Manage situs (limit Geneva real/tangibles), use charitable components where appropriate, document debts/expenses, and line up liquidity for the assessment due date.
How do I handle a pending sale of Geneva property?
Coordinate appraisals and timing; after assessment/payment, request a tax clearance certificate to satisfy land-registry and banking requirements.