Question juridique clé
Whether a donation made as an advance on inheritance to a direct-line heir benefits from the tax relief of Art. 10A LDS.
Solution extraite
Yes. Donations inter vivos and successions must be treated identically for tax purposes; therefore an advance-on-inheritance donation to a direct-line heir falls within the relief of Art. 10A LDS.
Motifs extraits
The court relied on the consistent intent throughout Geneva tax legislation to treat successions and donations inter vivos in the same manner.