Holding. For a decedent domiciled abroad, Schaffhausen taxed SH-situs real estate (apartment/chalet) at date-of-death market value; foreign intangibles stayed outside scope.

Reasoning. Immovable property’s situs is where located; intangibles follow the decedent’s domicile unless tied to a Schaffhausen permanent establishment.

Practice point. Attach land-register extract and independent appraisal; align FX/methodology with foreign filings.

Holding. Spouse/registered partner and direct descendants benefitted from statutory relief; unrelated beneficiaries were taxed on their shares at progressive rates.

Reasoning. Rate classes depend on relationship; relief applies before communal modifiers are considered.

Practice point. Split bequests to favoured classes where appropriate; include civil-status evidence to substantiate relief.

Holding. Only debts allocable to SH-situs property (e.g., the property’s mortgage) reduced the SH base; general estate liabilities were excluded.

Reasoning. Requires functional nexus between liability and SH asset; avoids double deduction inter-cantonally.

Practice point. Provide lender statements as of date of death and show linkage to the SH parcel.

Holding. Material lifetime gifts shortly before death were considered in allocating beneficiary burdens under anti-avoidance principles.

Reasoning. Prevents circumvention of class-based burdens; timing and intent scrutinised.

Practice point. Document gift dates/values and relationships; anticipate queries for transfers within look-back windows.

Holding. A well-supported minority/illiquidity discount was accepted for a non-listed shareholding based on an independent expert valuation.

Reasoning. Fair market value at date of death; discount justified by control and marketability constraints.

Practice point. Commission a Swiss-practice-aligned report; reconcile with foreign estate values to avoid mismatches.

Holding. Where probate proceeded abroad, a limited SH return covering only SH-situs assets sufficed; foreign assessments supported credit claims.

Reasoning. Inter-cantonal/foreign coordination principles prevent double taxation; SH jurisdiction follows situs.

Practice point. Include foreign assessment letters and payment proofs; ensure consistent asset lists across filings.