2023 Year-end Swiss Tax Update

Year-end Swiss Tax Update

Raise a glass to 2023 – a vintage year for tax developments!

It’s been a bustling period with a rich bouquet of legislative proposals and directives, both in the realm of Swiss taxation and on the global stage.

As we approach the year’s end, we are pleased to share our newsletter regarding pivotal Swiss tax developments that impact both individuals and entities, also with a focus on fiscal transparency developments.

By reading this newsletter at a pace of one page a day, you’ll be well-versed in tax discussions for 2024 before the year ends! For targeted insights, our highlighted sections will guide you swiftly to your topics of interest.

Individual Tax Updates:


  1. Family Taxation Reform: Aiming for fairness, the proposal for individual married couple taxation awaits a March 2024 parliamentary review.
  2. Divorce Taxation : As marriages sometimes end, Geneva addresses fairness anew, promising equal treatment for separated or divorced parents from January 1, 2024.
  3. Work Tool Taxation: Addressing the tax burden, Geneva proposes relief, pending legislative approval.
  4. Cross-border Teleworking: after extended dialogue, Switzerland has secured lasting tax agreements with two neighboring states, Italy and France. We note, however, for the French cross border workers, a mismatched rhythm with the new European social security regulation which Switzerland is a party to.
  5. Real Estate Tax : Geneva is poised for change with a 2% real estate capital gains tax on properties held for over 25 years, though implementation should be deferred to 2025. Moreover, Geneva’s tax administration has adjusted its practice following a crucial Federal Tribunal decision on December 13, 2022, concerning the tax treatment of French SCIs.
  6. Rental value taxation : The Swiss National Council has finally made a pivotal move towards tax reform by voting to abolish imputed rental value taxation. Will 2024 truly witness its abolition? The current critiques of the project cast doubt on its future.
  7. Lump sum taxation : The regime continues to attract wealth, despite varying international stances on residency status according to the double tax treaties. Crypto-assets : New SFTA provisions on NFTs and Airdrops reflect the evolving digital asset landscape.

Corporate Tax Highlights:

8.Among news, the changes in VAT rates effective from January 1, 2024, have not gone unnoticed. We also welcome the abolition of the Geneva municipal business tax, offset by a slight increase in Geneva’s corporate profit tax rate – a change that will please advocates of the BEPS project’s second pillar.
9. BEPS 2.0: New global minimum tax : Will the ordinance to introduce a minimum tax rate of 15% come into force on January 1, 2024? The anticipation is palpable, and we must confess: the answer, unfortunately, won’t be found in our newsletter!

Tax transparency initiatives :

10. Swiss UBO registry : Can Switzerland proceed without a central UBO registry? The Swiss Federal Council reignites the debate with the consultation procedure on a draft law aimed at enhancing the transparency of legal entities.
11. AEOI for Crypto-Assets: The expansion of the Automatic Exchange of Information to crypto-assets is underway, signaling a new frontier in tax transparency.


With these curated insights, we invite you to stay informed and prepared for the discussions ahead.

Happy holiday wishes and a fruitful New Year!



The Boitelle Tax Team 

20 December 2023 Authors : Sarah Meriguet,

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