Grisons Wealth Tax Valuation
Grisons (Graubünden) Wealth Tax: Valuation Rules
Grisons values assets generally at fair market value, with specific cantonal rules for real estate, business assets, securities, life insurance and patents under the Graubünden Steuergesetz.
In Grisons, wealth tax (Vermögenssteuer) is levied on a taxpayer’s net assets at 31 December. The cantonal Steuergesetz (StG) and the Graubünden Kantonsblatt for natural persons summarise how assets are valued for wealth tax purposes (Art. 55–61 StG; section “Bewertung des Vermögens”).
As the Kantonsblatt explains, assets (Aktiven) are generally valued at fair market value (Verkehrswert). However, insurance, securities and real estate can be subject to special valuation rules, and business assets are taken at the value relevant for income tax.
1. General Valuation Principle
The Graubünden Kantonsblatt summarises Art. 55–61 StG as follows:
- General rule: Assets are in principle valued at fair market value (Verkehrswert).
- Special rules: For insurance, securities and real estate, other valuation methods may apply.
- Business assets: The business assets of a taxpayer are valued at the value relevant for income tax (tax balance sheet value).
2. Real Estate (Art. 56–57 StG)
Real estate is treated as a key “cantonal particularity” in the Kantonsblatt for Grisons. For wealth tax, the following rules apply:
- Residential and commercial buildings: Under Art. 56(2) StG, these are valued at the mean of (i) market value and (ii) twice the earnings value of the last three years. In practice, this creates a blended tax value between capital and income perspectives.
- Monuments and heritage properties: Art. 56(4) StG allows buildings of historical or heritage significance, where preservation demands sacrifices from the owners, to be taxed mainly based on earnings value.
- Agricultural land: Art. 57(3) StG provides that agricultural properties which were acquired for speculative or investment purposes (or obviously serve these) are taxed according to the same rules as other properties (Art. 56 StG) rather than at pure agricultural income values.
3. Securities & Receivables
The Kantonsblatt notes that alternative valuations can apply to securities, and the Graubünden tax administration has issued a specific practice note for unlisted securities. In summary:
- Listed securities: Shares, funds and bonds are valued at their 31 December market price, usually based on the Federal Tax Administration’s (ESTV) official year-end price list.
- Unlisted securities (private companies): According to the practice document “Bewertung nicht kotierter Wertpapiere”, Graubünden values unlisted securities for private wealth in principle under the Swiss Tax Conference Circular KS 28 (practitioner method). Shareholder agreements may be taken into account where relevant.
- Receivables: Generally at nominal value; for clearly doubtful or contested receivables, the loss probability may be reflected via value adjustments if appropriately documented.
4. Unlisted Shares & Private Companies (KS 28 Framework)
Where no official Graubünden tax value is already published for a given participation, the KS 28 practitioner method typically applies:
- Net asset value (NAV): Book equity adjusted for hidden reserves and off-balance-sheet items.
- Earnings value: Average sustainable profit capitalised with a factor reflecting risk and sector.
- Combined value: Often a weighted average of NAV and earnings value is used as the wealth tax value per share.
In practice, you should:
- Provide 2–3 years of financial statements, including notes.
- Explain exceptional items and any normalisation of earnings.
- Ensure all shareholders in Grisons apply the same tax value for consistency across assessments.
5. Business Assets & Patents (Art. 55–61, 62a StG)
The Kantonsblatt states that business assets are valued at the value used for income tax. This means:
- Movable business assets and intangibles are taken at their tax balance sheet values after tax-accepted depreciation and provisions.
- Hidden reserves embedded in business assets can remain for wealth tax purposes as long as the tax balance sheet is accepted.
- Business real estate is still subject to the Art. 56 blend between market and earnings value, but within the business context.
Grisons also includes a specific patent-related wealth tax relief:
- Under Art. 62a StG, the net business wealth is reduced in proportion to qualifying patents and comparable rights (as per Art. 18c StG) relative to total business assets.
- This mirrors the Graubünden “patent box” approach in income tax and can materially lower the wealth tax base for IP-heavy businesses.
6. Life & Annuity Insurance
The Graubünden Kantonsblatt lists rückkaufsfähige Lebens- und Rentenversicherungen explicitly as part of taxable wealth (object of the wealth tax):
- Life insurance and refundable annuity contracts with a surrender value are included at their surrender value (Rückkaufswert) as at 31 December.
- Pure risk insurance without a surrender value is generally not treated as wealth.
- Occupational pension assets (2nd pillar) and tied 3a assets remain wealth-tax exempt until payout.
7. Other Assets
All remaining assets follow the general rule of valuation at fair market value unless a specific statutory rule applies:
- Cash & bank deposits: Nominal CHF balances at year-end.
- Precious metals: Bullion-valued according to year-end market prices.
- Art & collectibles: Realistic fair value; appraisals and insurance values are recommended for significant collections.
- Motor vehicles, boats, aircraft: Secondary market value based on price guides or dealer estimates.
- Cryptoassets: Not yet expressly codified in Graubünden law, but typically treated like financial assets and valued at observable year-end rates (e.g. FTA crypto list or recognised exchanges).
8. Foreign Assets & Exchange Rates
Residents of Grisons are subject to wealth tax on their worldwide net assets. Foreign assets must therefore be included:
- Foreign bank accounts, portfolios and receivables are valued at local year-end values and converted into CHF, generally using the FTA’s official year-end exchange rates.
- Foreign real estate is valued based on local market and income values and then converted into CHF for Grisons wealth tax; allocation across cantons/countries follows Swiss inter-cantonal practice.
- Keep original foreign statements plus a record of the FX rates used to avoid later disputes.
9. Liabilities & Net Wealth (Art. 62–63 StG)
The Kantonsblatt explains that gross wealth minus debts equals net wealth, and that net wealth minus personal allowances yields taxable wealth:
- Mortgages and other bank loans for which the taxpayer is personally liable are deductible at their nominal value at 31 December.
- Joint debts, guarantees and similar obligations are deductible only to the extent the taxpayer must economically bear them.
- Foreign-currency debts are converted to CHF using the same year-end exchange rates applied to foreign assets.
After subtracting debts, the remaining net wealth is reduced by Grisons’ allowances (e.g. CHF 138,000 for married couples and CHF 69,000 for others plus child allowances) before applying the progressive wealth tax scale.
10. Timing & Measurement Date
Graubünden uses the calendar year as the tax period. Wealth tax is assessed on the asset position at the end of the tax period, i.e. normally 31 December:
- The valuation date for all assets and liabilities is 31 December of the tax year.
- For business owners with non-calendar financial years, the balance sheet closing within the tax period governs the valuation of business assets, consistent with income tax rules.
- Where tax liability in Grisons exists only for part of the year (e.g. entry or exit during the year), the Steuergesetz provides for prorated taxation; the valuation principle itself remains tied to the year-end position.
11. Planning Takeaways
- Real estate valuation blend: The Art. 56 formula (mean of market value and twice the three-year earnings value) makes rental yield and usage key drivers of the wealth tax base in Grisons.
- Heritage & agricultural property: Earnings-value-driven taxation and special rules for speculative agricultural land should be considered in long-term succession and redevelopment planning.
- Business & IP: Because business assets follow the income-tax balance sheet and Graubünden grants patent-linked relief on net business wealth, IP structuring and accounting policies directly influence the wealth tax burden.
- Unlisted shares: KS 28-based valuations and the Graubünden practice on shareholder agreements should be applied consistently across shareholders and years to avoid disputes.
- Interaction with allowances: Combining accurate asset valuations, debt allocation and cantonal allowances (married/single/children) is often more impactful than marginal valuation differences. Use the Wealth Tax Calculator to model Grisons outcomes.
