Fribourg Corporate & Capital Tax
Last updated: 11 Dec 2025
Fribourg Corporate & Capital Tax — Business Tax Overview
How corporate income tax and capital tax work in the Canton of Fribourg for companies: who is taxed, what is taxed, how rates are built up, where Fribourg sits in the Swiss landscape, and where to dive deeper (profit tax, capital tax, rates, cases, calculator, and forms & deadlines).
Fribourg at a Glance
Position in the Swiss tax landscape
Fribourg is a bilingual canton (French/German) between Lausanne and Bern with a competitive mid-range corporate tax environment:
- Corporate income tax rates (cantonal/communal plus federal) are generally in the mid-teens to upper-teens for standard companies, depending on commune, year and use of reliefs.
- Capital tax on equity exists and should be modelled, particularly for holding, real estate and capital-intensive structures.
- The canton hosts industrial, agri-food, logistics and service businesses, with accessible tax authorities and a pragmatic ruling practice.
Key features for companies
| Tax types | Cantonal/communal profit tax, cantonal/communal capital tax, federal corporate income tax. |
| Taxpayers | Capital companies (AG, GmbH / SA, Sàrl), cooperatives, certain foundations and associations. |
| Profit tax base | Taxable profit derived from statutory accounts with tax adjustments. |
| Capital tax base | Equity (including reserves and hidden equity), with reliefs for certain assets. |
| STAF tools | Participation relief, patent box, R&D deductions and related measures. |
Who Is Taxed & On What?
- Aziende residenti. Companies with their statutory seat or effective place of management in Fribourg are subject to responsabilità fiscale illimitata on their worldwide income and equity, with exemptions or credits for foreign permanent establishments and real estate under Swiss and treaty rules.
-
Entità non residenti.
Nonresident companies are subject to responsabilità fiscale limitata in Fribourg on profit and
equity attributable to:
- Permanent establishments in Fribourg; and/or
- Fribourg–situs real estate or business assets.
- Legal forms in scope. The rules in this hub primarily address juristische Personen / personnes morales (AG/SA, GmbH/Sàrl, cooperatives). Partnerships and sole proprietors are taxed via personal income tax and are not the focus here.
- Periodo fiscale. For juristic persons, the tax period generally follows the financial year. Year-end changes or extended first years require coordination with the tax office.
Corporate Income Tax vs. Capital Tax
Fribourg, like other Swiss cantons, taxes companies entrambi on their annual profit and on their equity. Understanding the distinction is key for planning.
| Aspetto | Corporate income tax (profit tax) | Capital tax (equity tax) |
|---|---|---|
| Base imponibile | Taxable profit for the year (after adjustments and loss offsets). | Equity attributable to Fribourg (share capital, reserves, hidden equity). |
| Economic focus | How much the company earns. | How strongly the company is capitalised and where assets reside. |
| Driver principali | Business model, margins, transfer pricing, reliefs. | Financing mix (equity vs debt), participations, IP, real estate and industrial assets. |
| Interaction | Profit tax may be credited or coordinated with capital tax in special cases. | Often functions as a minimum tax in low-profit or loss years. |
| Where to read more | Fribourg corporate tax | Fribourg capital tax |
For many Fribourg companies, the combined profit and capital tax burden is dominated by profit tax. But for holding structures, early-stage companies and capital-intensive entities, capital tax can be a meaningful additional cost or a binding minimum, and should be modelled explicitly.
Indicative Rate Level & Competitiveness
Where do Fribourg rates sit?
While exact figures depend on tax year, commune, and use of reliefs, Fribourg is typically viewed as:
- In the competitive mid-range of Swiss corporate tax cantons;
- Attractive for operating companies with real substance, particularly in industry, agri-food, logistics and services;
- Able to offer tailored solutions for holdings, IP and financing entities via modern STAF instruments and bilingual ruling practice.
For statutory parameters and trends over time, see the Tariffe page, which summarises simple rates, tax factors and minimum tax rules.
Quick modelling
To get a first feel for the combined tax burden (cantonal, communal and federal) on your company’s profit and equity:
- Use this hub’s Fribourg tax calculator for an approximate estimate; and
- Cross-check with the official cantonal company tax calculator.
For restructuring, relocations or major investments, these tools are a starting point. A tailored model and, where appropriate, an advance tax ruling are usually the next step.
STAF, IP & Special Situations
Fribourg has implemented the Swiss corporate tax reform (STAF) and provides a toolbox of reliefs and instruments that can materially change the effective tax rate for qualifying companies.
| Strumento | Cosa fa | Where to look |
|---|---|---|
| Sgravio di partecipazione | Reduces the effective tax burden on qualifying dividends and capital gains from shareholdings in subsidiaries. | Explained in depth on the imposta sulle società page (participation income section). |
| Patent box | Allows qualifying IP income to be taxed at a reduced level, subject to nexus and tracking requirements. | Particularly relevant for IP companies and R&D structures described in the casi section. |
| R&D deductions | Provide additional deductions for qualifying R&D expenses, lowering the profit tax base. | Discussed in both the imposta sulle società e casi pagine. |
| Capital tax relief | Certain assets (e.g. participations, IP) may benefit from reduced capital tax exposure, especially in holding or IP-heavy structures. | Vedi imposta sul capitale and the planning aspects on the tariffe pagina. |
These instruments are powerful but documentation-heavy. For material structures, Fribourg practice typically involves an advance ruling that coordinates cantonal and federal tax treatment.
Compliance Workflow in Practice
For a typical Fribourg company (AG/SA o GmbH/Sàrl), the recurring tax workflow looks roughly like this:
| Passo | What happens | Where to read more |
|---|---|---|
| 1. Year-end closing | Financial statements are prepared and approved; key tax-sensitive items (provisions, depreciation, related-party transactions) are identified. | Internal accounting, auditors, group tax. |
| 2. Tax return preparation | Fribourg corporate tax return (juristic persons) is prepared (often via e-filing tools), including profit-to-tax reconciliation and capital tax base. | Moduli e scadenze |
| 3. Filing & payment | The return and financials are signed and filed; advance payments are reconciled; any remaining tax is paid within deadlines. | Moduli e scadenze |
| 4. Assessment & follow-up | Combined cantonal/communal and federal assessments are issued. If needed, objections are filed within the stated period. | Corporate & capital tax interactions: imposta sulle società, imposta sul capitale. |
| 5. Planning & rulings | For restructurings, IP or financing changes, models are updated and rulings are prepared with the Fribourg and federal authorities. | Casi & Fribourg Tax Service |
Domande frequenti
Is Fribourg a high- or low-tax canton for companies?
Fribourg is generally in the competitive mid-range of Swiss corporate tax cantons. It is not among the very lowest-tax cantons, but can be attractive for industrial, agri-food and service businesses that value its bilingual environment and location between Lausanne and Bern.
Do I always pay both profit tax and capital tax in Fribourg?
Yes, for companies in scope, both are levied each year, but the relative weight varies. In profitable years, profit tax dominates; in low-profit or loss years, capital tax or a minimum tax may be the binding element. Special regimes and STAF instruments can change the mix for holdings and IP structures.
How important are advance tax rulings in Fribourg?
For routine annual filings, rulings are not usually needed. For structuring questions (holdings, IP, financing, relocations, major restructurings), rulings are common and provide valuable certainty, especially when multiple cantons or countries are involved.
Can I manage Fribourg corporate tax from abroad?
Many groups manage Swiss corporate tax centrally and work with local advisors for Fribourg compliance and rulings. Returns can often be prepared electronically and filed by post; communication with the tax office is possible via representatives. Substance, governance and documentation remain key, particularly for IP and financing structures.
Where do I start if I am considering a move to Fribourg?
A typical sequence is: (1) high-level rate comparison and effective tax modelling; (2) review of substance, functions and people; (3) structuring concept (legal form, holding / IP / finance set-up); and (4) pre-filing discussions and rulings with the Fribourg tax authorities. The Fribourg Tax Service is designed to support exactly this path.
Discuss your Fribourg corporate tax position (Sesch TaxRep GmbH) Contatto