Zum revidierten Erbkollisionsrecht

Gian Andri Capaul

The new rules in international inheritance law of the Swiss Private International Law Act, which have been
in force since 1 January 2025, bring numerous changes for estate planning in Switzerland. This article focuses
on the three different types of decedents for which the Swiss legal system created a different set of rules. The
aim is to provide an overview of the law applicable on the succession for each of them. The text discusses objective connecting factors and the choice of law by the parties. These remarks are embedded in their jurisdictional context. With regard to the applicable law, the choice of law restriction for Swiss multinationals has to be critically examined. Although this is merely a selective encroachment on party autonomy, it causes the revised rules to fall short of its initially intended goals. These included, for example, harmonisation with the European Succession Regulation and the moderate expansion of party autonomy.