3 Swiss Net Wealth Tax General principles of Swiss net wealth taxation and top wealth tax rates 2019

This publication contains general information with regard to various topics that may be of interest for Swiss and foreign high-net-worth-individuals and/or family owned businesses. For individual, case related information and enquiries, please contact one of our tax and legal specialists from the Swiss FOB & PW team.

FOB & PW SWITZERLAND General Swiss Net Wealth Taxation Principles

. Annual net wealth tax is levied on whole worldwide wealth at cantonal and communal level.

. The applicable tax rates are progressive and vary depending on the canton and commune. The tax rates usually range between 0.1% to a maximum of 1% of the net assets.

. The net wealth tax basis consists of all assets and rights at their fair market value, minus debts and certain deductions. The value of foreign-situs immovable property and foreign-situs permanent establishment are excluded. However, immovable properties located abroad are considered when setting the applicable tax rate.

. Net wealth tax may under conditions be levied on the non-resident owner, e.g. on the owner of business assets in a permanent establishment or immovable property situated in Switzerland.

. Any income / wealth of the spouse and minor children is included in the taxable income and wealth (joint and not separate filing and taxation)

. Some cantons provide for a so-called tax shield (bouclier fiscal) where a taxpayer’s income and wealth tax burden exceeds a certain portion of the taxpayer’s taxable income (e.g. canton of Valais). The tax shield mitigates the impact of the taxpayer’s wealth tax.

. Net wealth tax is also levied for taxpayers taxed under the lump-sum regime. To determine the wealth tax basis the cantons apply different approaches, e.g. the wealth tax basis is included in the income tax basis (e.g. canton of Vaud), the income tax basis is increased by a certain percentage (e.g. canton of Geneva) or the wealth tax basis is a multiple of the income tax basis (e.g. canton of Valais).

Loyens & Loeff – FOB & PW – Zurich – 14 February 2020 - General information 2 Top Net Wealth Tax Rates 2019

0.44% 0.47% 0.80% 0.29% 0.76% 0.66% 0.57% 0.25% 0.21% 0.26% 0.41% 0.68% 0.44%

0.58% 0.35% 0.79% 0.28% 0.60% 0.32% 0.14% 0.23% 0.13% 1.00% 0.20% 0.63% 0.58%

Ordinary top net wealth tax rates, capital city, for 2019, indicative

Loyens & Loeff – FOB & PW – Zurich – 14 February 2020 - General information 3 Disclaimer

This publication does not constitute tax or legal advice and the contents thereof may not be relied upon. Although this publication was composed with the greatest possible diligence, all entities, branch offices, partnerships, persons and practices trading under the name “Loyens & Loeff” cannot accept liability or responsibility for the results of any actions taken on the basis of this publication without their cooperation, including any errors or omissions.

Loyens & Loeff – FOB & PW – Zurich – 14 February 2020 - General information 4