Complementing VB 26078, position VB 26081 was published on 22 September 2026 (decision 7 September 2026) addressing a specific variant of a kanscontract where the annuity is indexed or the care obligation is variable. The ruling provides detailed guidance on the actuarial valuation of non-fixed counter-performances for inheritance tax purposes.
Key Takeaways
- Indexation Increases Actuarial Value: Periodic indexation of the annuity based on consumer prices increases the present value of the counter-performance, reducing the taxable gift component. The administration prescribes specific discount rates for such calculations.
- Variable Care Obligations: Where the care obligation fluctuates (e.g., depending on health status), the administration requires a probability-weighted scenario analysis using medical actuarial standards to determine the expected value.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement