Uri Capital Tax
Last updated: 15 Dec 2025
Uri Capital Tax — Equity Tax Rules
How capital tax works for companies in the Canton of Uri: who is subject to municipal equity tax, how the taxable capital base is determined, how the per-mille rate range and the cantonal minimum tax operate, how burdens vary by municipality, and how capital tax interacts with corporate income tax.
Scope & Taxpayers
- Resident companies. Capital tax applies to companies with statutory seat or effective place of management in Uri (AG, GmbH, cooperatives and other juristische Personen), on their equity allocable to the canton. The tax is levied only at municipal level; Uri does not levy a separate cantonal capital tax.
- Nonresident entities. Nonresident companies with a permanent establishment or Uri–situs real estate are subject to capital tax on the equity attributable to those Uri assets and operations, again via the municipality where the establishment or property is located.
- Tax period and valuation date. Capital tax is assessed annually, generally based on the equity at the end of the business year as shown in the statutory accounts, subject to tax adjustments (e.g. hidden equity).
- Legal form. The rules on this page focus on capital companies and cooperatives. Associations, foundations and other entities with ideal or charitable purpose may benefit from equity thresholds (no capital tax on the first CHF 100,000 of equity) and from exemptions where tax-privileged.
Tax Base: Equity & Hidden Equity
For Uri municipal capital tax, the taxable base is equity as defined in the cantonal tax act (share capital and reserves, open and hidden), subject to specific adjustments and reliefs.
| Component | Included? | Comment |
|---|---|---|
| Share/paid-in capital | Yes | Fully included in the capital tax base for AGs and GmbHs, based on the registered commercial register amount. |
| Open reserves | Yes | Legal reserves, voluntary reserves and retained earnings form part of taxable equity. |
| Hidden reserves (including goodwill) | Yes, in principle | To the extent that assets are carried below tax values or significant hidden reserves exist, Uri practice can require adjustment, particularly in restructurings, migrations or transactions with related parties. |
| Revaluation reserves | Yes | Revaluation reserves and step-up amounts become part of equity and hence the capital tax base once recorded. |
| Non-business assets | Yes | Private or non-business assets held within the company are fully subject to capital tax and may impact profit tax as well (e.g. deemed income, limited deductibility of related costs). |
| Hybrid instruments & shareholder loans | Partially | Excessive shareholder loans may be recharacterised as hidden equity under thin-capitalisation rules, increasing the capital tax base and affecting interest deductibility for profit tax. |
| Participations, IP & intra-group loans | Yes | Equity attributable to participations, IP or intra-group loans forms part of the capital tax base. Uri does not have a specific statutory reduction of the capital tax base for these items, but participation relief and STAF instruments are relevant on the profit tax side. |
The precise capital tax base is determined under the Uri tax act (Steuergesetz des Kantons Uri) and cantonal practice. For groups, allocation of equity between Uri and other cantons or foreign jurisdictions is a critical step and should follow consistent allocation keys aligned with the group’s profit allocation.
Municipal Rates, Range & Minimum Tax
Municipal capital tax framework
Uri stands out by not levying any cantonal capital tax on ordinary companies. Instead, capital tax is charged exclusively at the level of the municipalities.
Key parameters:
- Municipalities must set a simple capital tax rate between 0.01 ‰ and 4.0 ‰ of taxable equity.
- This simple rate is then multiplied by the municipal tax factor (Steuerfuss) to arrive at the effective municipal capital tax.
- The canton-wide framework and the minimum/maximum range are defined in the Uri tax act; each municipality chooses its own rate and tax factor within this range.
In practice, promotional material for Uri highlights very low capital tax in central municipalities such as Altdorf (simple rate of 0.01 ‰), placing Uri among the lowest-capital-tax cantons for ordinary companies.
For current per-mille rates and tax factors by municipality and year, use:
- The official Uri tables on simple rates, municipal capital tax and tax factors under Steuersätze und Tarife, and
- The Rates page and calculator of this hub.
Minimum tax & entity-specific rules
Uri applies a minimum tax (Minimalsteuer) for juristic persons:
- If a company’s combined canton, municipal and church taxes on profit and capital for a tax year are below CHF 500, it must instead pay a minimum tax of CHF 500.
- The minimum tax applies even in cases of limited tax liability (e.g. permanent establishments) and is due for the full tax period in the year of in- or out-migration.
- Certain entities (e.g. some self-help cooperatives without profit motive, qualifying associations and foundations) are exempt from the minimum tax or from capital tax on the first CHF 100,000 of equity.
The effective capital tax burden therefore depends on:
- The municipality (per-mille rate and tax factor),
- The level of equity, and
- Whether regular profit and capital tax exceed the CHF 500 minimum in a given year.
For ordinary capital companies and cooperatives, Uri’s combination of low municipal capital tax rates and a flat profit tax means that capital tax is often a relatively small component of the overall burden.
Interaction with Profit Tax
Capital tax in Uri is closely coordinated with corporate income tax. A few key points:
- Same return, separate bases. Profit tax is levied on taxable income; capital tax is levied on equity. Both are calculated using the same corporate tax return for juristic persons, but with different schedules.
- Flat profit tax, proportional capital tax. Uri applies a linear (flat) cantonal and municipal profit tax rate to taxable profit for capital companies, while capital tax is proportional to equity at the municipal per-mille rate.
- Minimum tax overlay. The CHF 500 minimum tax looks at the overall burden from profit and capital tax combined. For loss-making or very low-profit companies, this minimum can be the binding burden despite low capital tax rates.
- Participation relief. Profit tax on qualifying dividends and capital gains can be heavily reduced via participation relief, especially in holding or investment structures, while capital tax remains due on the underlying equity.
- STAF interaction. Uri implements Swiss corporate tax reform (STAF) through reduced profit tax rates, participation relief and transitional rules for hidden reserves, but retains the municipal capital tax regime with its wide 0.01 ‰–4.0 ‰ range.
For the profit tax side, see the Uri corporate tax page and the combined tax calculator.
Planning Points & Typical Cases
| Theme | Capital tax angle | Typical actions |
|---|---|---|
| Municipality choice within Uri | Municipal tax factors and capital tax per-mille rates vary between communes. For the same canton-wide framework, the capital tax burden can differ significantly across Uri. | Compare combined profit and capital tax (including churches) for relevant municipalities (e.g. Altdorf, Andermatt). Use official tables and calculators when choosing or reassessing a corporate domicile. |
| Financing structure | More equity means higher capital tax but less thin-cap risk, while high shareholder debt can be challenged and reclassified as hidden equity. | Review intra-group financing; align with Swiss thin-capitalisation practice; document arm’s-length interest rates and security; model combined profit and capital tax under different equity levels and municipalities. |
| Holding & investment structures | Participation relief on qualifying dividends and capital gains can strongly reduce profit tax, while the municipal capital tax burden on the underlying equity remains very low in many Uri communes. | Assess whether Uri is an attractive holding or investment location compared with other low-tax cantons; obtain rulings where necessary (e.g. for complex group structures, relocations or use of transitional regimes). |
| IP & R&D | IP-rich companies may face higher equity and hence capital tax, but enjoy profit tax instruments such as patent box and R&D deductions at cantonal level where applicable. | Map IP assets and functions; ensure robust valuation and cost tracking; coordinate Uri profit and municipal capital tax optimisation; align with substance and nexus requirements. |
| Start-ups & low-profit years | In loss-making or low-profit years, the CHF 500 minimum tax may override the otherwise very low municipal capital tax. | Factor the minimum tax into cash flow projections; monitor when regular profit and capital tax begin to exceed the minimum; use ruling processes for larger investments or relocations. |
| Restructurings & migrations | Changes of seat, mergers or de-mergers may crystallise hidden reserves and trigger special profit tax rules; municipal allocation of equity determines capital tax in and out of Uri. | Plan transactions early; prepare pro-forma balance sheets and allocation scenarios; coordinate rulings with departure and arrival cantons as well as the federal tax authorities. |
Compliance Snapshot
Capital tax is assessed and collected together with corporate income tax for juristic persons. For procedural detail, see the dedicated Forms & deadlines page. Key points include:
| Area | Key points |
|---|---|
| Return | Annual corporate tax return for juristic persons, filed via the Uri tax administration’s electronic systems or approved software, includes both profit and capital tax sections. Municipal capital tax is determined within the same return. |
| Deadline | Same filing deadline as for profit tax (standard deadlines are set canton-wide and can be extended on request). The equity position at year-end and any allocation to Uri must be documented for the same period. |
| Documentation | Balance sheet; equity reconciliation; details of participations, IP, intra-group loans and major revaluations; analysis of hidden equity and shareholder loans where relevant; confirmation of the municipality and applicable capital tax rate. |
| Assessments & objections | A single assessment covers profit and capital tax (cantonal and municipal). Objections must clearly distinguish issues relating to the profit tax base, the capital tax base, the municipal per-mille rate and tax factor, and the application of the minimum tax. |
FAQs
What is taxed under Uri capital tax?
Uri capital tax is levied, at municipal level, on the company’s equity attributable to the canton: share capital, open reserves, retained earnings and, where relevant, hidden equity and revaluation reserves. Certain entities (e.g. associations and foundations) benefit from thresholds or exemptions, but ordinary capital companies are fully subject to capital tax on their taxable equity.
Does Uri levy cantonal capital tax?
No. The Canton of Uri does not levy a separate cantonal capital tax on ordinary companies. Capital tax is charged only by the municipalities as a percentage (per-mille) of taxable equity, within a cantonal range of 0.01 ‰ to 4.0 ‰, plus the canton-wide minimum tax of CHF 500 where the combined burden is lower.
How is the municipal capital tax rate determined?
The Uri tax act sets a framework: municipal simple capital tax rates must be between 0.01 ‰ and 4.0 ‰ of taxable equity. Each municipality then sets its own simple per-mille rate and tax factor (Steuerfuss) within this range. The effective capital tax burden therefore depends on both the municipality and the tax year.
Is there a minimum tax for companies in Uri?
Yes. Juristic persons that, in a given year, pay less than CHF 500 in combined cantonal, municipal and church taxes (profit and capital) are subject to a minimum tax of CHF 500. Certain self-help cooperatives as well as some associations and foundations are exempt from this minimum tax, subject to conditions in Uri law.
Can Uri capital tax be reduced through planning?
Within legal limits, yes. Typical levers include choosing the right municipality within Uri, optimising equity vs. debt, managing the location and structure of holdings and IP, and coordinating Uri profit tax (including participation relief and STAF instruments) with municipal capital tax. Any planning must be consistent with substance, transfer pricing and Swiss anti-avoidance practice.
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