The case
The ruling is about a case, where an estate was divided unequally among heirs.
Source: Steuer Rekursgericht Zürich, 8. April 2024, 85.2023.6; rechtskräftig / ZStP 4/2024 page 332f f.
The commentary
In principle, heirs are bound by the order of a last will or inheritance contract. Differing agreements among heirs can be considered so-called inter-heir donations (Querschenkung) which are subject to taxes. If heirs agree, this can be relevant and acceptable for inheritance tax law if it helps remove any serious doubts about the inheritance law situation on condition that the agreement does not obviously help avoid taxes.
Each respective part of the estate that an heir obtains is subject to taxes and it is irrelevant whether it is e.g. real estate or cash.
Real estate abroad is not subject to taxes in the cantons though it is consulted to determine the rate. If heirs take over property aboad, they remain subject to taxes within their part of the inheritance.
The rules listed above refer to §§ 3 Abs. 1 und 2, 7 lit. a, 8 Abs. 1 of Erbschafts- und Schenkungssteuergesetzes (ESchG) of the canton of Zurich.