What Changes as of 2026 in Switzerland

At the start of 2026, we have summarized the tax measures now in force and the reforms that will shape the coming months, both in Switzerland and internationally.

 

1. Cross-border remote work

The 40% remote work threshold for Switzerland–France / Switzerland–Italy becomes permanent.

At the same time, the Federal Act on the Automatic Exchange of Information regarding Salary Data (LEADS), expected no earlier than May 1, 2026, lays the groundwork for the automatic exchange of salary data. From 2027 onward, Swiss and French (and Italian) tax authorities will exchange 2026 salary data of cross-border employees, as previously submitted by employers.

For employers, this implies strict monitoring of remote work rates, consistency between payroll–tax–social security matters, and enhanced documentation.

 

2. CRS 2.0 & crypto-assets

As of 2026, Switzerland introduces CRS 2.0 / CARF, extending the automatic exchange of information to crypto-assets. Intermediaries will be required to identify their clients, determine their tax residence, and transmit data to the Swiss Federal Tax Administration (FTA). The first international exchange will take place in 2027, once partner states are approved and agreements activated.

In this context, on January 15, 2026, the Swiss Federal Tax Administration revised the directive relating to the Standard for Automatic Exchange of Information in Tax Matters (AEOI – financial accounts), clarifying the technical requirements applicable to Swiss financial institutions.

Alignment of transparency for digital assets with that of traditional financial assets.

 

3. Pillar Two – automatic exchange of GloBE Information Returns (GIR)

In 2026, Switzerland continues the implementation of Pillar Two under the “side-by-side” approach. U.S. groups are formally excluded from the scope of the Swiss IIR, reflecting the U.S. position not to transpose Pillar Two rules into domestic law.

In parallel, Switzerland is preparing for the filing and automatic exchange of GloBE Information Returns (GIR), expected no earlier than mid-2026, subject to international ratification.

 

4. Tax interest rates for 2026

For 2026, late payment and refund interest for direct federal tax are set at 4.0%, while voluntary advance payments are no longer remunerated (0.0%).

 

5. Individual pension provision (pillar 3a): new retroactive buy-ins

Following an amendment to the Federal Ordinance on Tax-Deductible Contributions to Recognized Forms of Pension Provision (OPP 3), approved by the Federal Council, it is now possible as of 2026 to retroactively close contribution gaps in pillar 3a for years starting from 2025.

A strengthened planning tool, particularly relevant in the context of the gradual increase of the reference retirement age for women to 65.

 

6. Lump-sum taxation: new taxable bases for 2026

The minimum taxable base for direct federal tax (DFT) is set at CHF 435,000. In the canton of Geneva, the minimum base amounts to CHF 468,993 for cantonal and communal tax (CCT), and CHF 451,200 (CCT) in the canton of Vaud.

 

7. Philanthropy – Geneva

In November 2025, the Geneva tax authorities updated their Guide on Tax Exemptions for associations and foundations, clarifying the practice applicable to institutions pursuing a public-interest purpose. This update confirms the conditions for exemption from cantonal and communal tax as well as the rules on the deductibility of donations.

Enhanced legal certainty for public-interest institutions and donors.

 

8. Zug: temporary reduction of cantonal tax

The canton of Zug applies a temporary reduction of the cantonal tax coefficient (78% instead of 82%) for the period 2026–2029, accompanied by an expansion of certain deductions (for insurance premiums and retirees).

 

9. Geneva: targeted real estate reassessment of tax values

Geneva increases the tax value of villas and condominium units by 12% for the 2025 tax period.

Immediate impact on 2026 tax returns, in particular on wealth tax.

 

What Will Shape Switzerland’s Agenda in 2026 (Outlook and Debates)

10. Individual taxation – referendum of March 8, 2026

A fundamental reform is being submitted to a popular vote: individual taxation based on a single rate scale, aimed at achieving tax equality between married and unmarried couples, together with enhanced child deductions to support the labor market participation of the second income earner.

If accepted, new planning opportunities will arise, particularly for dual-income households. A review of the situation of lump-sum taxed taxpayers will also be necessary, as each household member would be taxed separately.

 

11. Real estate taxation – secondary residences

The reform related to the abolition of the imputed rental value and the possible introduction of a cantonal real estate tax on secondary residences will continue to fuel the political agenda. Two reforms are progressing:

• Abolition of the taxation of imputed rental value as of 2028
• Passive (mortgage) interest generally no longer deductible as of 2028
• Possible introduction of a cantonal real estate tax on secondary residences

 

12. VAT – temporary increase under discussion

To finance the 13th AHV/AVS pension, an increase of 0.7 percentage points (to 8.8%) is being discussed for the period 2026–2030. Similarly, discussions are being held to increase the VAT with (another) 0.8 percentage points to finance the strengthening of Switzerland’s security and defence capabilities.

 

13. Loss carryforward

On December 19, 2025, Parliament approved the principle of extending the loss carryforward period to 10 years. Legislative implementation and entry into force will need to be closely monitored, with application expected no earlier than January 1, 2027.

 

14. Corporate transparency (LTPM)

Expected in the second half of 2026, the future law on corporate transparency provides for the creation of a centralized register of beneficial owners, with targeted obligations (in particular for trustees).

Foundations and associations are expected to remain outside the scope of application.

 

International trends – mobility and wealth transparency

The OECD is accelerating on two fronts:

15. International mobility of individuals

The consultation launched at the end of 2025 on international mobility of individuals highlights the scale of challenges linked to remote work, cross-border workers, and hybrid models. The project covers both income tax (residence, double taxation, withholding obligations, allocation of taxation rights on salaries) and corporate tax (permanent establishment risks, place of effective management, profit attribution).

This approach reflects the intention to modernize tax rules designed for a world in which economic activity was geographically stable.

 

16. Increased transparency of real estate assets: towards a “real estate CRS”

In parallel, the OECD is developing a framework aimed at integrating foreign real estate into the automatic exchange of information, similar to CRS for financial accounts. The objective is to enable tax authorities to identify real estate held abroad by their residents, their economic users, and ownership structures (direct or via entities).

This initiative extends international transparency far beyond financial accounts and crypto-assets.

Tax cooperation is evolving toward global transparency, covering salaries, crypto-assets, financial and real estate wealth.

 

2026 confirms a more transparent and more coordinated tax environment.

The BOITELLE TAX team remains at its clients’ side to transform these developments into secure and well-managed decisions.

 

3 February 2026 Authors : Thierry Boitelle, Antoine Pioger, Sarah Meriguet, Marine Antunes,

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