Geneva Corporate & Capital Tax
Ultimo aggiornamento: 09 dic 2025
Geneva Corporate & Capital Tax — Business Tax Overview
How corporate income tax and capital tax work in the Canton of Geneva for companies: who is taxed, what is taxed, how rates are built up (including an indicative combined profit tax level around 14.7% and imputed capital tax on equity), where Geneva sits in the Swiss landscape, and where to dive deeper (profit tax, capital tax, rates, cases, calculator, and forms & deadlines).
Geneva at a Glance
Position in the Swiss tax landscape
Geneva offers a internationally visible business environment with reformed, but still mid-to-upper Swiss range corporate tax levels:
- Following corporate tax reform (RFFA/STAF), ordinary Geneva companies typically face a combined (cantonal/communal plus federal) corporate income tax rate of around 14.7% on profit before tax, depending on commune and year.
- Capital tax on equity is levied at a modest rate (roughly in the low 0.4–0.6% range), but is in practice largely imputed against profit tax once profit reaches a certain percentage of equity.
- Geneva’s economy is highly international: finance, trading, commodities, NGOs, international organisations, watchmaking and services. Tax practice is sophisticated, with extensive use of advance rulings for structuring.
Key features for companies
| Tax types | Cantonal/communal profit tax, cantonal/communal capital tax (imputed), federal corporate income tax. |
| Taxpayers | Capital companies (SA/AG, Sàrl/GmbH), cooperatives, certain foundations and associations. |
| Profit tax base | Taxable profit derived from statutory accounts with tax adjustments, including RFFA/STAF reliefs. |
| Capital tax base | Equity (including reserves and hidden equity) attributable to Geneva, with profit tax often credited against capital tax. |
| RFFA/STAF tools | Participation relief, patent box, additional R&D deductions and related instruments. |
Who Is Taxed & On What?
- Aziende residenti. Companies with their statutory seat or effective place of management in Geneva are subject to responsabilità fiscale illimitata on their worldwide income and equity, with exemptions or credits for foreign permanent establishments and foreign real estate under Swiss and treaty rules.
-
Entità non residenti. Nonresident companies are subject to
responsabilità fiscale limitata in Geneva on profit and equity attributable to:
- Permanent establishments in Geneva; and/or
- Geneva-situs real estate or business assets.
- Legal forms in scope. This hub focuses on persone morali / persone giuriste (SA/AG, Sàrl/GmbH, 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, migrations or extended first years should be coordinated with the Geneva tax administration.
Corporate Income Tax vs. Capital Tax
Geneva, like other Swiss cantons, taxes companies entrambi on their annual profit and on their equity. The mechanics in Geneva are shaped by the RFFA reform and the imputation of capital tax against profit tax.
| Aspetto | Corporate income tax (profit tax) | Capital tax (equity tax) |
|---|---|---|
| Base imponibile | Taxable profit for the year after adjustments, participation relief, patent box and R&D deductions. | Taxable equity attributable to Geneva (share capital, open and hidden reserves, certain provisions). |
| Economic focus | How much the company earns in or allocated to Geneva. | How strongly the company is capitalised and where assets (especially real estate and participations) are located. |
| Driver principali | Business model, margins, transfer pricing, use of RFFA/STAF reliefs, location of functions and risks. | Financing mix (equity vs debt), size and nature of participations, IP, cash and Geneva real estate. |
| Interaction | Profit tax is computed on taxable profit and typically dominates the overall burden for profitable entities. | Capital tax is often imputed against profit tax. In many cases, once profit reaches a modest percentage of equity, profit tax exceeds capital tax and the latter becomes largely a minimum tax. |
| Where to read more | Geneva corporate tax | Geneva capital tax |
For many Geneva companies, the combined profit and capital tax burden is driven primarily by profit tax. However, for holding structures, asset-rich entities and early-stage companies with low profits, capital tax and minimum tax rules can still be relevant and should be modelled explicitly.
Indicative Rate Level & Competitiveness
Where do Geneva rates sit?
While exact figures depend on tax year, commune, profit level and use of reliefs, Geneva is typically viewed as:
- A reformed, competitive international hub, with a combined profit tax rate around the mid-teens (≈14.7%) including the federal layer.
- More expensive than Switzerland’s very lowest-tax cantons, but offering an attractive balance of rates, infrastructure and international ecosystem.
- Particularly suitable for headquarters, trading, finance and service companies that value Geneva’s location, labour market and international institutions.
For statutory parameters, communal multipliers and trends over time, see the Tariffe page, which summarises simple rates, tax factors and minimum tax rules for Geneva.
Quick modelling
To get a first feel for the combined tax burden (cantonal, communal and federal) on your company’s profit and equity in Geneva:
- Use this hub’s Geneva tax calculator for an approximate estimate; and
- Cross-check with official cantonal company tax calculators if you need a more precise view.
For restructurings, relocations or major investments, these tools are a starting point. A tailored model and, where appropriate, an advance tax ruling with the Geneva tax office are usually the next step.
RFFA/STAF, IP & Special Situations
Geneva has implemented the Swiss corporate tax reform (RFFA, the Geneva implementation of 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 (classic holding and group structures). | 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. Important for Geneva-based IP and R&D structures with real substance. | 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 and effective rate for innovation-driven businesses. | Discussed in both the imposta sulle società e casi pagine. |
| Capital tax relief & imputation | Capital tax is levied on equity but can be credited against profit tax in Geneva. For companies with sufficient profitability, this greatly reduces the practical impact of capital tax; for low-profit years, it sets a minimum burden. | Vedi imposta sul capitale and planning aspects on the tariffe pagina. |
These instruments are powerful but documentation-heavy. For material structures (holdings, IP, financing, relocations), Geneva practice typically involves an advance ruling that coordinates cantonal and federal tax treatment and, where relevant, clarifies the interaction with other cantons and countries.
Compliance Workflow in Practice
For a typical Geneva company (SA/AG o Sàrl/GmbH), 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, transfer pricing, related-party transactions) are reviewed under Geneva and federal rules. | Internal accounting, auditors, group tax. |
| 2. Tax return preparation | The Geneva corporate tax return is prepared, including profit-to-tax reconciliation, capital tax base and any RFFA/STAF instruments (patent box, additional R&D deduction). | 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. Minimum tax and capital-tax-imputation rules are checked. | Moduli e scadenze |
| 4. Assessment & follow-up | Combined cantonal/communal and federal assessments are issued. If needed, objections or appeals are filed within the stated period, and positions are coordinated with other cantons and jurisdictions. | Corporate & capital tax interactions: imposta sulle società, imposta sul capitale. |
| 5. Planning & rulings | For restructurings, IP or financing changes, relocations into or out of Geneva or major investments, models are updated and rulings are prepared with Geneva and federal authorities. | Casi & Geneva Tax Service |
Domande frequenti
Is Geneva a high- or low-tax canton for companies?
After reform, Geneva sits in a competitive mid-range by Swiss standards: combined profit tax around 14–15% is higher than the very lowest-tax cantons, but remains attractive in an international context. For groups that value Geneva’s international environment, labour market and infrastructure, the overall package is often compelling.
Do I always pay both profit tax and capital tax in Geneva?
Yes, for companies in scope, both are technically levied each year, but the relative weight varies. In profitable years, profit tax usually dominates and capital tax is largely imputed; in low-profit or loss years, capital tax / minimum tax can be the binding element. RFFA/STAF instruments can further change the mix for holdings and IP structures.
How important are advance tax rulings in Geneva?
For routine annual filings, rulings are not usually needed. For structuring questions (holdings, IP, financing, relocations, major investments), rulings are very common and provide valuable certainty, especially when several cantons or countries are involved.
Can I manage Geneva corporate tax from abroad?
Many groups manage Swiss corporate tax centrally and work with local advisors for Geneva compliance and rulings. Returns can 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 that rely on Geneva entities.
Where do I start if I am considering a move to Geneva?
A typical sequence is: (1) high-level rate comparison and effective tax modelling for Geneva vs. alternative cantons; (2) review of substance, functions and people; (3) structuring concept (legal form, holding / IP / finance set-up in or via Geneva); and (4) pre-filing discussions and rulings with the Geneva tax authorities. The Geneva Tax Service e il Geneva Business Tax Service are designed to support exactly this path.
Discuss your Geneva corporate tax position (Sesch TaxRep GmbH) Contatto