International families often have ties to several countries, and the law of each of them may claim to govern their marriage, their estate or their divorce. The articles collected here explain marriage contracts and matrimonial property regimes, the choice of law for succession under Swiss private international law, forced heirship and how it can be planned for, and the recognition of foreign divorces and judgments in Switzerland. They are written for families from Asia, the Middle East and Africa who live in Switzerland or hold assets there, and for their advisers at home.
When an international family lives in Switzerland, Swiss private international law decides which law governs the marriage, the estate and a possible divorce. The family can choose the applicable law in many cases, which makes careful planning possible and helps avoid conflicting outcomes in different countries.
Swiss private international law allows spouses to choose the law of a state in which both are domiciled or of which one of them is a national to govern their matrimonial property. A foreign national living in Switzerland can generally subject his or her estate to the law of a state of nationality. These choices help families keep their arrangements consistent across the countries where they live and hold assets.
Wills, marriage contracts and corporate structures need to fit together. A marriage contract concluded in one country may not be recognised in the same way elsewhere, and Swiss forced heirship rules may apply to an estate governed by Swiss law. The reform of 2023 reduced the compulsory shares, which gives testators more freedom to leave a business or other assets to selected heirs.
Families from Asia, the Middle East and Africa often hold assets through companies, trusts or foundations in several jurisdictions. Switzerland recognises foreign trusts under the Hague Trust Convention, even though Swiss law has no domestic trust of its own. Coordinating these structures with matrimonial and succession planning protects family members and reduces the risk of disputes between heirs in different countries.
The articles explain matrimonial property regimes and marriage contracts, the choice of law for succession, the reform of forced heirship in 2023, the jurisdiction of Swiss courts in divorce, and the coordination of family planning with trusts and foundations.
Forced heirship in Switzerland after the 2023 reform
Since 1 January 2023 Swiss forced heirship rules leave more room for the testator. What children and spouses can still claim, and how abatement works. Read more Private Client · SuccessionChoosing the law that governs your estate in Switzerland
Foreign nationals living in Switzerland may, under certain conditions, subject their estate to their national law. How a professio iuris works and where caution is needed. Read more Private Client · SuccessionWills and inheritance contracts in Switzerland
Handwritten will, public will or inheritance contract: the forms available under Swiss law, the role of the executor and how documents made abroad are treated. Read more Private Client · Family LawMatrimonial property regimes in Switzerland
Participation in acquired property, separation or community of property: the Swiss regimes, how marriage contracts are made and what happens to regimes chosen abroad. Read more Private Client · Family LawPrenuptial and marriage agreements for international couples
A prenuptial agreement signed in Hong Kong, Dubai or Lagos may not have the effect in Switzerland that the couple expects. Recognition, choice of law and drafting points. Read more Private Client · Family LawInternational divorce in Switzerland
Which court is competent, which law applies and how maintenance and pension splitting work when an international couple divorces in Switzerland. Read more Private Client · Family LawChildren in cross-border families
Parental responsibility, relocation abroad, child abduction and maintenance: how Swiss law and international conventions protect children in international families. Read more Private Client · SuccessionSuccession planning for family businesses in Switzerland
Transferring a family company to the next generation requires coordination of corporate law, forced heirship and cantonal gift and inheritance tax. Read more Private Client · Family LawInternational families in Switzerland: marriage contracts, succession and divorce
International families often have ties to several countries: the spouses may hold different nationalities, their children may live abroad, and… Read more