Switzerland-Ireland Cross Border Inheritance Tax Guide
Last updated: 30 Sep 2025
Switzerland × Ireland: Inheritance & Gift Tax — No IHT Treaty
Switzerland and Ireland have no bilateral inheritance/gift tax treaty. Double-tax mitigation relies on Ireland’s CAT (unilateral/double-tax credits) and Switzerland’s cantonal regimes (no Swiss federal IHT). The CH–IE income tax treaty exists but does not govern inheritance/gift taxes.
Ireland maintains CAT reliefs even without a treaty; in Switzerland, taxation (and exemptions) are cantonal—spouses are generally exempt, many cantons broadly exempt children.
At a glance
Key facts
- No CH–IE IHT treaty. Relief via Irish CAT credit/unilateral relief and Swiss cantonal mechanics.
- Swiss IHT is cantonal (no federal tax); spouses usually exempt, many cantons exempt children.
Why it matters
- Correct situs classification and documentation drive credits and reduce double taxation.
- CAT is beneficiary-based with lifetime aggregation since 5 Dec 1991.
Ireland: CAT basics
| Item | Rule (current) | Notes |
|---|---|---|
| Rate | 33% on taxable benefit | After applying lifetime threshold (Group A/B/C) |
| Thresholds | Since 2 Oct 2024: Group A €400k, Group B €40k, Group C €20k | Aggregate prior gifts/inheritances since 5 Dec 1991 |
| Returns | Form IT38 | Deadlines & Pay-and-File dates per Revenue |
Switzerland: cantonal regimes
- No federal inheritance/gift tax; levied by cantons/communes.
- Spouses are generally exempt; many cantons broadly exempt children.
- Rates, bases, and procedures vary widely—see our canton-by-canton overview.
Situs drivers (high level)
| Asset | Situs (typical) | Comments |
|---|---|---|
| Immovable property | Where located | Primary taxing right usually at situs |
| Tangible movables | Physical location at death/transfer | Document location at key date |
| Bank claims / deposits | Debtor location (bank) | Statements + bank domicile evidence |
| Shares / stock | Place of incorporation | Swiss AG/GmbH → CH; Irish LTD/PLC → IE |
Double-tax relief in practice (no treaty)
- Ireland (CAT):
- Credit for Double Taxation where the same property is taxed abroad and in Ireland (documentation & caps apply).
- Unilateral Relief can apply even without a treaty, subject to Revenue rules and evidence.
- Switzerland: Relief (if applicable) is determined at the cantonal level; many cases end up with no Swiss tax on spouse/children, so the burden often sits on the Irish CAT side for foreign-situs assets.
Documentation matters: valuations at death, situs evidence, foreign assessments and proofs of payment drive any credit capacity.
Worked example (numbers)
- Decedent: Swiss resident in Canton Zurich.
- Heir: Adult child resident in Ireland (Group A).
- Assets:
- Swiss brokerage account (Zurich bank): CHF 900,000 (assume ≈ €900,000)
- Irish bank deposit: €150,000
- Assumptions (illustrative only): Zurich exempts children from inheritance tax; ignore debts/other reliefs.
Aggregate benefits since 5 Dec 1991. Apply Group A threshold (€400,000). CAT @ 33% on excess.
Both the Irish deposit (IE-situs) and the Swiss portfolio (foreign-situs) enter the CAT computation for an Irish-resident beneficiary.
CAT will chiefly remain on the Irish side (subject to thresholds/aggregation).
Illustration only (rounded; ignores spouse/charity/business reliefs, debts, FX, valuations). Actual outcomes depend on precise canton rules, values and filings (IE IT38).
Planning checklist (no legal/tax advice)
- Identify canton (Swiss exemptions vary) and IE beneficiary status early.
- Map assets by situs (CH vs. IE) and type; model CAT thresholds & aggregation.
- Test credits under Irish rules; in many CH child-heir cases, there’s no Swiss tax to credit.
- Paper the file: valuations, situs evidence, official assessments and proof of payment (if any).
- Sequence lifetime gifts vs. bequests; consider IE’s aggregation since 5 Dec 1991.
FAQ
Is there a Switzerland–Ireland inheritance/gift tax treaty?
No. Relief is via Irish CAT credit/unilateral rules and Swiss cantonal mechanics; the CH–IE income tax treaty does not govern inheritance/gift tax.
Do Swiss cantons always tax inheritances?
No. Spouses are generally exempt and many cantons broadly exempt children. Always check the relevant canton.
What are the current Irish CAT thresholds and rate?
Rate: 33%. Thresholds since 2 Oct 2024: Group A €400,000; Group B €40,000; Group C €20,000. Confirm on Irish Revenue before filing.
Talk to us
We model IE × CH exposures, align canton rules, and prepare documentation for credits/relief.
