A federal initiative is aiming to introduce a national inheritance and gift tax of 20%. The inheritance tax would be levied on the estate of individuals who had their last residence in Switzerland or on estates which are opened in Switzerland. The fact that lifetime gifts from 1 January 2012 onward would be added retroactively to the estate and be taxed as well, causes an immediate estate planning issue as of today.
To date, there is no federal inheritance tax in Switzerland. If the initiative is adopted, this would change earliest from 1 January 2015, more probably from 1 January 2016. The federation would tax all inheritances and gifts that exceed the tax-free amount of two million Swiss francs with a tax of 20%. What also would remain tax exempt is the part of the estate and gifts bequeathed to the wife, husband or registered partner. Further reductions are envisaged in case of transfer of businesses or agricultural operations.