Kernrechtsfrage
Whether the transfer of business inventory qualified as an inheritance advance / lifetime gift under § 24 StG.
Extrahierter Entscheid
The transfer qualified as a lifetime gift (mixed gift/inheritance advance) because the inventory was transferred as a whole, the parties had an inheritance relationship, and the gift element exceeded 10% of the transfer value.
Extrahierte Begründung
For business transfers to a presumptive heir, the transfer must be assessed as a whole. A gift component above 10% of the transfer value meets the long-standing criteria for a lifetime gift; the individual items need not all be transferred on identical terms.