Ticino Corporate & Capital Tax
Ultimo aggiornamento: 09 dic 2025
Ticino Corporate & Capital Tax — Business Tax Overview
How corporate income tax and capital tax work in the Canton of Ticino for companies: who is taxed, what is taxed, how rates are built up (from historically higher levels towards a more moderate mid-teens range after recent reforms), where Ticino sits in the Swiss landscape, and where to dive deeper (profit tax, capital tax, rates, cases, calculator, and forms & deadlines).
Ticino at a Glance
Position in the Swiss tax landscape
Ticino is an Italian-speaking canton with a historically higher mid-range corporate tax level, which is being reduced in stages to stay competitive:
- Ordinary companies (e.g. in Lugano or Bellinzona) have traditionally faced combined corporate income tax rates (cantonal/communal plus federal) in the upper mid-teens to around 19% on profit before tax, depending on commune and year.
- Recent reforms and planned reductions bring headline rates down, with Ticino positioning itself as a more attractive location within the Italian-speaking region, and with some municipal locations offering particularly competitive environments.
- Capital tax on equity exists at moderate levels and interacts with profit tax so that in profitable years the overall burden is usually driven by profit tax.
- Ticino’s economy combines finance and asset management, trading, cross-border services, industry, tourism and logistics, with strong ties to Lombardy and northern Italy.
Key features for companies
| Tax types | Cantonal/communal profit tax, cantonal/communal capital tax, federal corporate income tax. |
| Taxpayers | Capital companies (SA/AG, SAGL/GmbH), cooperatives, certain foundations and associations. |
| Profit tax base | Taxable profit derived from statutory accounts with tax adjustments, loss offsets and STAF instruments. |
| Capital tax base | Equity (including reserves and hidden equity) attributable to Ticino, with reliefs and potential interaction with profit tax. |
| STAF tools | Participation relief, patent box, additional R&D deductions and other reliefs as implemented by Ticino. |
Who Is Taxed & On What?
- Aziende residenti. Companies with their statutory seat or effective place of management in Ticino 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 Ticino on profit and equity attributable to:
- Permanent establishments in Ticino; and/or
- Ticino-situs real estate or business assets.
- Legal forms in scope. The rules in this hub primarily address persone giuridiche / persone giuriste (SA/AG, SAGL/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 Ticino tax administration and, where relevant, other cantons.
Corporate Income Tax vs. Capital Tax
Ticino, like other Swiss cantons, taxes companies entrambi on their annual profit and on their equity. The interactions can be relevant for holding, financing and asset-heavy structures.
| Aspetto | Corporate income tax (profit tax) | Capital tax (equity tax) |
|---|---|---|
| Base imponibile | Taxable profit for the year (after adjustments, participation relief, patent box, R&D deductions and loss offsets). | Equity attributable to Ticino (share capital, open and hidden reserves, certain provisions) valued under cantonal rules. |
| Economic focus | How much the company earns in or allocated to Ticino. | How strongly the company is capitalised and where key assets (especially real estate, participations and IP) reside. |
| Driver principali | Business model, margins, transfer pricing, location of people and decision-making, and use of STAF instruments. | Financing mix (equity vs debt), size and nature of participations, IP, cross-border structures, and Ticino real estate. |
| Interaction | Profit tax is computed on taxable profit. For qualifying income (participations, IP, R&D), STAF reliefs can significantly reduce the effective tax rate. | Capital tax often functions as a imposta minima in low-profit or loss years. In profitable years, depending on detailed Ticino rules and commune, profit tax may overshadow or partially reduce the practical impact of capital tax. |
| Where to read more | Ticino corporate tax | Ticino capital tax |
For many Ticino companies, the combined profit and capital tax burden is dominated by profit tax. However, for holding structures, real-estate vehicles, finance companies and early-stage entities with low profits, capital tax and minimum tax mechanisms can still be a binding constraint and should be modelled explicitly.
Indicative Rate Level & Competitiveness
Where do Ticino rates sit?
While exact figures depend on tax year, commune, profit level and use of reliefs, Ticino is typically viewed as:
- A mid- to higher-tax canton by Swiss standards, with historical combined profit tax rates for standard companies in the upper mid-teens to around 19% on profit before tax, but with planned and ongoing reductions aimed at keeping Ticino competitive.
- More expensive than Switzerland’s classic low-tax cantons of Central Switzerland, but still competitive compared with many international locations and neighbouring jurisdictions across the border.
- Particularly interesting for businesses that benefit from Ticino’s geography (Italian-speaking workforce, access to Lombardy, road and rail links) and are prepared to work with its tax environment via modelling and rulings.
For statutory parameters and trends over time, see the Tariffe page, which summarises simple rates, tax factors and minimum tax rules for Ticino and key municipalities.
Quick modelling
To get a first feel for the combined tax burden (cantonal, communal and federal) on your company’s profit and equity in Ticino:
- Use this hub’s Ticino tax calculator for an approximate estimate; and
- Cross-check with the Swiss Federal Tax Administration calculator and cantonal tools for more detailed scenarios.
For restructurings, relocations or major investments, these tools are a starting point. A tailored model and, where appropriate, an advance tax ruling with the Ticino tax office are usually the next step, particularly for cross-border, IP and group-financing structures.
STAF, IP & Special Situations
Ticino has implemented the Swiss corporate tax reform (STAF / TRAF) and provides a toolbox of reliefs and instruments that can materially change the effective tax rate for qualifying companies, especially in IP-, R&D- or holding-heavy structures.
| Strumento | Cosa fa | Where to look |
|---|---|---|
| Sgravio di partecipazione | Reduces the effective tax burden on qualifying dividends and capital gains from shareholdings in subsidiaries. Central for holding and group financing companies in Ticino. | 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. Useful for Ticino-based IP and R&D structures with real substance. | Particularly relevant for IP companies described in the casi section. |
| R&D deductions | Provide additional deductions (beyond normal expenses) for qualifying R&D expenditure, 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 | Certain assets (e.g. participations, IP) may benefit from privileged treatment for capital tax, and the interaction between profit tax and capital tax can reduce the residual capital tax burden for profitable Ticino companies. | Vedi imposta sul capitale and planning aspects on the tariffe pagina. |
These instruments are powerful but documentation-heavy. For material structures (cross-border holdings, IP, treasury, real estate), Ticino practice typically involves an advance ruling that coordinates cantonal and federal tax treatment and, where relevant, clarifies the interaction with other cantons and foreign jurisdictions.
Compliance Workflow in Practice
For a typical Ticino company (SA/AG o SAGL/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, cross-border arrangements, related-party transactions) are reviewed with Ticino corporate and capital tax rules in mind. | Internal accounting, auditors, group tax. |
| 2. Tax return preparation | The Ticino corporate tax return is prepared, including profit-to-tax reconciliation, capital tax base and any STAF instruments (patent box, additional R&D deduction). Intercantonal and international allocation questions are addressed where relevant. | 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 interactions 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 foreign tax authorities (especially Italy and other EU states). | Corporate & capital tax interactions: imposta sulle società, imposta sul capitale. |
| 5. Planning & rulings | For restructurings, IP or financing changes, relocations into or out of Ticino, cross-border moves or major investments, models are updated and rulings are prepared with Ticino and federal authorities. | Casi & Ticino Tax Service |
Domande frequenti
Is Ticino a high- or low-tax canton for companies?
Ticino has traditionally been in the upper mid-range of Swiss corporate tax cantons, with combined profit tax rates higher than the classic low-tax cantons of Central Switzerland but lower than Switzerland’s most expensive cantons. Recent and planned reforms are gradually reducing the effective burden, particularly for ordinary companies with substantial operating substance.
Do I always pay both profit tax and capital tax in Ticino?
Yes, for companies in scope, both are levied each year, but the relative weight varies. In profitable years, profit tax usually dominates and may significantly reduce the practical impact of capital tax; in low-profit or loss years, capital tax or a minimum tax can be the binding element. STAF instruments (such as patent box and R&D deductions) can change the mix for holdings and IP structures.
How important are advance tax rulings in Ticino?
For routine annual filings, rulings are not usually needed. For structuring questions (holdings, IP, financing, relocations, cross-border arrangements, major restructurings or large investments), rulings are common and provide valuable certainty, particularly where several cantons or countries (notably Italy) are involved.
Can I manage Ticino corporate tax from abroad?
Many groups manage Swiss corporate tax centrally and work with local advisors for Ticino 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 cross-border, IP and financing structures that rely on Ticino entities.
Where do I start if I am considering a move to Ticino?
A typical sequence is: (1) high-level rate comparison and effective tax modelling for Ticino vs. alternative cantons and foreign locations; (2) review of substance, functions and people in the proposed Ticino structure; (3) structuring concept (legal form, holding / IP / finance set-up in or via Ticino); and (4) pre-filing discussions and rulings with the Ticino tax authorities. The Ticino Tax Service is designed to support exactly this path.
Discuss your Ticino corporate tax position (Sesch TaxRep GmbH) Contatto