Europe’s great inheritance fights are being settled in Swiss villages and Hong Kong banks

On 11 September a judge in Turin made a decision that took a paragraph to report and years to reach. Margherita Agnelli, daughter of the late Fiat patriarch Gianni Agnelli, could not join the criminal case against her son John Elkann as a civil party.

She was admitted, however, in the part of the case concerning documents about the ownership of Dicembre, the family company at the top of the chain that controls Exor, Ferrari and Stellantis.

The case itself turns on an address. Prosecutors allege that Marella Caracciolo, Gianni Agnelli’s widow, who died in 2019, was registered as resident in Switzerland while in fact living in Turin, with the result that tax was not paid in Italy on her estate.

In September 2025 Elkann and his siblings agreed to pay €183mn to the Italian tax agency. A judge in February refused to let him close the criminal case with a year of community service, and prosecutors have asked for a trial. His lawyers say he is “entirely unconnected” to the alleged offences.

The Agnelli dispute is unusual only in its scale. Look at the great European and Chinese inheritance fights of the past two years and the same pattern appears. The money is argued over in one country, and decided in another.

A will signed in Switzerland

Alain Delon died in August 2024 at his estate in Douchy, south of Paris. He had lived in Switzerland for decades and held Swiss citizenship, and his last will was signed there. It left his daughter Anouchka 51 per cent of the company that manages his image and the moral rights to his work.

His youngest son, Alain-Fabien, went to a French court to have the will annulled, arguing that his father was not in a fit state to sign it. On 9 March, days before the hearing, he suspended the French case to pursue the matter in Switzerland, where the will was made.

A Valais village and a Geneva court

Nicolas Puech, the Hermès heir whose stake worth about $10bn has disappeared, lives in the Swiss canton of Valais. His case against the adviser who managed his fortune for decades was heard in Switzerland, where a court ruled in 2024 that the adviser could not be held responsible.

Puech is now suing LVMH and Bernard Arnault in France.

An HSBC account in Hong Kong

The Chinese version of the pattern runs through Hong Kong. Zong Qinghou, founder of the beverage group Wahaha, died in 2024. Three children from a relationship outside his marriage say he set up a $2.1bn offshore trust for them through HSBC in Hong Kong.

His eldest daughter, Zong Fuli, who runs the family’s drinks business, disputes their claim.

A Hong Kong court froze about $1.8bn in the account in 2025. On 21 July the Court of Appeal refused Zong Fuli leave to appeal, leaving the money locked until the main case, in Hangzhou, is decided.

Why it keeps happening

Very rich families use Switzerland and Hong Kong for good reasons: stable courts, discreet banks, predictable tax and no inheritance tax at all in many Swiss cantons for direct descendants. The same structures that keep a fortune private while its founder is alive make its division contentious once they die.

The result is a peculiar geography of grief. A French film star’s image rights are decided by Swiss procedure. An Italian dynasty’s tax bill depends on whether a widow truly lived in a chalet in the Bernese Oberland. A Chinese drinks fortune waits on judges in two jurisdictions.

For the lawyers involved, it is steady work. For the families, the offshore arrangements that were supposed to settle the question have become the question.

Sources

• AGI: Margherita Agnelli cannot be a civil party against John Elkann (11 Sep 2026)
• Reuters via Global Banking & Finance: Italian prosecutors seek trial for John Elkann (Apr 2026)
• Reuters via US News: judge rules Elkann can’t close the case with community service (11 Feb 2026)
• MilanoFinanza: €183mn paid to the tax agency (Sep 2025)
• CNews: why Alain-Fabien Delon suspended his challenge to his father’s will (9 Mar 2026)
• Caixin Global: Wahaha heiress loses Hong Kong appeal over $1.8bn freeze (22 Jul 2026)
• Wikipedia: Nicolas Puech

Cover image: Barbara Steinemann, Wikimedia Commons, CC BY-SA 4.0. Cropped.