Switzerland.
Switzerland operates a federal-cantonal split. The Zivilgesetzbuch (ZGB) governs the substance of succession at federal level, with Pflichtteil (compulsory share) under Articles 470–472 protecting descendants and the surviving spouse. The 2023 succession-law reform reduced the descendants’ compulsory share from three-quarters to one-half of their intestate share, increasing testamentary flexibility. Inheritance tax is levied at the cantonal level — there is no federal estate or inheritance tax — with rates and exemptions varying significantly across the 26 cantons.
The Bundesgesetz über das Internationale Privatrecht (IPRG) governs choice-of-law for cross-border estates. Swiss-resident decedents are subject to Swiss law unless they elect their national law under IPRG Article 90; foreign-resident Swiss nationals can elect Swiss law under Article 87. Switzerland is NOT party to EU Succession Regulation 650/2012. The 30 November 2025 federal referendum decisively rejected the JUSO initiative for a 50% federal inheritance tax on estates above CHF 50 million, preserving the cantonal-only regime.
The memoranda in this series address the recurring fact patterns in Swiss cross-border estate planning — including the post-2023 Pflichtteil reform, the cantonal inheritance-tax variation (Geneva up to 54.6%, Schwyz and Obwalden zero), the US–Switzerland 1951 Estate Tax Treaty mechanics, the IPRG choice-of-law framework outside Brussels IV, the Erbvertrag (inheritance contract) under Articles 494–504 ZGB, and the Lump-Sum Taxation (forfait fiscal) regime for inbound HNW individuals.