For inheritance tax purposes, the value of the entire property is usually determined first and then apportioned according to the inherited quota.

From a civil law perspective, it can be argued that a share of co-ownership alone is more difficult to sell than a complete property, which could justify a market discount – however, the tax authorities regularly do not recognize such a discount.

For a later realisation, such as the sale of the share to the co-heirs, this limited marketability can nevertheless be taken into account as part of the civil-law negotiation.

If the property is divisible in structural or legal terms, a partition in kind may be considered as an alternative to share valuation, whereby each co-heir receives a separate portion of the land.

However, a partition in kind often requires a new survey, possibly a division of the property under building law, and the consent of all parties involved, and is not practicable for every property.

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