Aargau Capital Tax
Last updated: 14 Dec 2025
Aargau Capital Tax — Equity Tax Rules
How capital tax works for companies in the Canton of Aargau (AG): who is subject to equity tax, how the taxable capital base is determined (including hidden equity), how the cantonal/communal rate mechanics and minimum tax work in practice, which relief themes matter (especially for participation-heavy structures), and how capital tax interacts with corporate income tax and compliance.
Scope & Taxpayers
- Resident companies. Capital tax applies to companies with statutory seat or effective place of management in Aargau (AG, GmbH, cooperatives and other juristische Personen), on their equity allocable to the canton.
- Nonresident entities. Nonresident companies with a permanent establishment in Aargau or Aargau-situs real estate are subject to capital tax on the equity attributable to those Aargau factors and operations (allocation matters).
- Tax period and valuation date. Capital tax is assessed annually with the corporate tax return. The balance sheet is the starting point, but tax-value adjustments and hidden equity can apply where accounts do not reflect tax values.
- Legal form. The rules on this page focus on capital companies and cooperatives. Associations, foundations and charitable entities may benefit from exemptions or separate capital tax rules depending on purpose and recognition.
Tax Base: Equity & Hidden Equity
For Aargau capital tax, the taxable base is equity attributable to Aargau: paid-in share capital and reserves (open and hidden), subject to cantonal adjustments, allocation rules, and relief mechanisms where applicable.
| Component | Included? | Comment |
|---|---|---|
| Share/paid-in capital | Yes | Included in the capital tax base for AGs and GmbHs based on registered amounts. |
| Open reserves | Yes | Legal reserves, voluntary reserves and retained earnings are part of taxable equity. |
| Hidden reserves (incl. goodwill) | Yes, in principle | Relevant where assets are carried below tax values or where transactions/migrations/restructurings trigger tax-value adjustments. |
| Revaluation / step-up reserves | Yes | Once recorded in equity, revaluations/step-ups increase the capital tax base (subject to any transitional treatment). |
| Non-business assets | Yes | Assets held within the company generally form part of taxable equity and can influence allocation and profit tax considerations. |
| Hybrid instruments & shareholder loans | Partially | Excessive shareholder loans may be recharacterised as hidden equity under thin-capitalisation practice, increasing taxable capital. |
| Participations & IP | Yes, but often relieved | Qualifying participations (and, depending on the situation, certain IP-related components) can drive relief themes. Profit-tax participation relief is separate, so model both profit and capital tax impacts. |
For multi-canton businesses, allocating equity between Aargau and other cantons (or foreign jurisdictions) is often the decisive technical step. Use consistent allocation keys and keep working papers aligned with the tax return.
Rates, Minimum Tax & Relief Themes
Standard rate & minimum tax
Aargau applies a capital tax on taxable equity. The effective burden depends on the statutory cantonal rate and the applicable cantonal/communal parameters (Steuerfuss / communal factors), which can vary by municipality and year.
Aargau also typically applies minimum tax concepts for juristic persons. If the combined outcome of profit and capital tax does not reach a statutory minimum, the minimum tax can apply, which becomes particularly relevant for low-profit or loss-making companies with meaningful equity.
For current-year effective figures (including the relevant factors), use:
- the hub Rates page, and
- official Aargau corporate tax tools/guidance for juristic persons where available.
Relief themes: participations, group structures, STAF instruments
For many Aargau profiles, the key question is not only the headline rate, but whether relief mechanisms apply and whether the company falls into a minimum-tax situation:
- Holding/participation-heavy companies. Participation relief reduces profit tax; capital tax (and minimum tax) can still be meaningful due to high equity.
- Group financing. Intra-group loans and shareholder debt can influence equity composition; thin-cap recharacterisation can increase taxable capital.
- STAF-aligned planning. Instruments such as patent box and R&D super-deduction affect profit tax; equity-rich structures still need capital tax modelling.
For complex holding, migration or financing cases, advance rulings are commonly used to confirm treatment and allocation.
Interaction with Profit Tax
Capital tax and corporate income tax are coordinated in Aargau. Key points:
- Same return, separate bases. Profit tax is levied on taxable income; capital tax is levied on taxable equity.
- Minimum tax can dominate. In low-profit/loss years, minimum tax mechanisms can make capital/minimum tax the binding cost.
- Equity vs. debt trade-off. More equity increases capital tax but reduces thin-cap risk; excessive shareholder debt can be reclassified as hidden equity (raising taxable capital anyway).
- Participation profiles. Participation relief can materially reduce profit tax, making capital tax more visible for holding-heavy structures.
For the profit tax side, see the Aargau corporate tax page and the combined tax calculator.
Planning Points & Typical Cases
| Theme | Capital tax angle | Typical actions |
|---|---|---|
| Financing structure | More equity generally means higher capital tax; excessive shareholder debt can be reclassified as hidden equity. | Review intra-group financing; run thin-cap checks; document arm’s-length interest, terms and security. |
| Holding structures | Participation relief can reduce profit tax; capital tax and minimum tax can become the binding burden for equity-heavy holdings. | Confirm participation qualification; model minimum tax outcomes; align substance, governance and allocation to Aargau. |
| Real estate & non-core assets | Real estate and non-core assets can create significant equity exposure and complex allocation (multi-canton). | Document valuations and allocation keys; consider ring-fencing strategies consistent with business substance. |
| Restructurings & migrations | Seat transfers, mergers or de-mergers can shift allocation keys and trigger tax-value/equity adjustments. | Plan early; prepare pro-forma balance sheets and allocation schedules; seek rulings where material. |
| Low-profit years | Capital tax/minimum tax can dominate overall tax cost when profit tax is low. | Model downside years; evaluate legal equity/debt rebalancing; maintain documentation to support the structure. |
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 includes both profit and capital tax schedules, typically prepared in the cantonal system for juristic persons. |
| Deadline | Deadlines typically follow the canton’s practice (often tied to year-end; extensions may be available). Equity documentation should match the same period. |
| Documentation | Balance sheet; equity reconciliation; participation schedules; related-party financing/thin-cap analysis; allocation schedules for multi-canton/foreign elements. |
| Assessments & objections | A single assessment often covers profit and capital tax. Objections should separate profit-tax base issues from equity/allocation/minimum-tax issues. |
FAQs
What is taxed under Aargau capital tax?
Aargau capital tax is levied on the company’s equity attributable to Aargau: share capital, open reserves, retained earnings and, where relevant, hidden equity. For multi-canton businesses, allocation rules determine the Aargau share of equity.
Does Aargau apply a minimum tax?
In practice, Aargau applies minimum tax concepts for juristic persons. For equity-heavy companies with low taxable profit, minimum tax can be the binding outcome and should be explicitly modelled.
How is the Aargau capital tax rate determined?
Aargau applies a statutory capital tax framework and the effective burden depends on cantonal and communal parameters (tax factors) that can vary by year and municipality. Use the hub Rates page and official tools for the current-year effective figures.
How does capital tax interact with corporate income tax in Aargau?
Profit tax and capital tax are computed on different bases but handled together in the annual return. Participation relief can reduce profit tax, while capital tax (and minimum tax) can remain meaningful for equity-heavy structures.
Can capital tax be reduced through planning?
Within legal limits, yes. Typical levers include optimising equity vs. debt (without triggering thin-cap recharacterisation), managing inter-cantonal allocation, and using rulings for complex holding, migration or financing cases.
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