Appenzell Innerrhoden Corporate & Capital Tax Rates
Last updated: 12 Dec 2025
Appenzell Innerrhoden Corporate & Capital Tax Rates
How corporate profit and capital tax rates work in the Canton of Appenzell Innerrhoden: a cantonal profit tax rate of 6.0% for companies (since 2020), a cantonal capital tax of 0.5‰ with a minimum of CHF 500 for capital companies, crediting of profit tax against capital tax, a combined effective corporate income tax burden of about 12.7% (including federal tax), and tools to model the tax load for companies.
Overview
Companies in Appenzell Innerrhoden pay a combination of:
- Cantonal, district and communal profit tax on taxable profit;
- Cantonal, district and communal capital tax on taxable equity; and
- Direct federal corporate income tax on profit.
Since the implementation of the Swiss corporate tax reform (STAF) from tax year 2020, Appenzell Innerrhoden has applied a flat profit tax rate of 6.0% for juristic persons at cantonal, district and communal level. In contrast to many other cantons, the law does not foresee a multiplication by a tax factor (Steuerfuss), so the statutory rate directly reflects the cantonal, district and communal burden.
The canton also levies a capital tax of 0.5‰ (0.05%) on corporate equity and guarantees a minimum capital tax of CHF 500 per year for capital companies (Kapitalgesellschaften). Profit tax is credited against capital tax, so that capital tax operates mainly as a minimum tax when profits are low or negative.
External comparisons quote a combined effective corporate income tax rate of around 12.66% in Appenzell Innerrhoden (including federal, cantonal and communal profit tax on profit before tax). This places the canton among the lowest-tax corporate locations in Switzerland, alongside Zug, Obwalden and Schwyz.
In addition to ordinary rates, Appenzell Innerrhoden has implemented a patent box, R&D additional deductions and a relief cap in line with STAF, but in a comparatively moderate form (e.g. a relatively small patent box relief).
Statutory Profit & Capital Tax Rates (Capital Companies & Cooperatives)
The table below summarises the main profit and capital tax parameters for Appenzell Innerrhoden capital companies around the STAF implementation. The focus is on ordinary capital companies and cooperatives (Kapitalgesellschaften und Genossenschaften).
| From / to | Cantonal profit tax for juristic persons | Cantonal capital tax for capital companies | Minimum capital tax | Comment |
|---|---|---|---|---|
| Until 31 Dec 2019 | Higher profit tax rates (around 8%) at cantonal, district and communal level for juristic persons, before STAF implementation. | Capital tax at 0.5‰ of taxable equity, but with parameters and interactions that were adjusted in the context of STAF. | Minimum capital tax rules existed, but at a level and with credit mechanisms that were updated as part of the reform. | Pre-STAF regime; corporate tax burden significantly higher than under the current 6.0% profit tax regime, though still relatively competitive by Swiss standards. |
| From 1 Jan 2020 | Flat profit tax rate of 6.0% of taxable net profit at the combined state, district and communal level for all juristic persons (including capital companies and cooperatives). | Capital tax rate of 0.5‰ (0.05%) of taxable equity for capital companies and cooperatives. No multiplication by a tax factor; the statutory rate applies directly. | Minimum capital tax of CHF 500 per year for capital companies in the canton. The profit tax is credited against capital tax, so that capital tax effectively functions as a minimum tax when profit tax is low. | STAF implementation: significant reduction of profit tax to 6.0%, adjustment of capital tax, introduction of patent box and R&D additional deductions and a relief cap to replace former preferential regimes. |
| From 1 Jan 2025 (current law & practice) | Profit tax for juristic persons remains at 6.0% of taxable net profit for the 2025 tax year, according to the latest economic promotion materials and cantonal communication. | Capital tax rate remains at 0.5‰ for capital companies and cooperatives; capital tax continues to be structured so that profit tax is credited against capital tax (with capital tax functioning as a minimum tax). | Minimum capital tax of CHF 500 per year for capital companies remains in place, with no capital tax levied on equity below CHF 50,000 for other juristic persons and certain collective investment schemes with direct real estate holdings. | Appenzell Innerrhoden ranks as one of the cantons with the lowest ordinary effective corporate income tax rates (around 12.66% combined), making it attractive for trading and holding companies, especially in the context of OECD Pillar 2 where rates below 15% are under scrutiny. |
The 6.0% profit tax rate and 0.5‰ capital tax rate for juristic persons in Appenzell Innerrhoden are set out in the cantonal tax act and in official economic promotion materials for 2025. When modelling specific cases, always check the current wording of the tax act, the cantonal website and any updated brochures.
Effective Combined Tax Burden
Cantonal/district/communal + federal
The effective corporate income tax rate in Appenzell Innerrhoden is obtained by stacking:
- Profit tax of 6.0% at the combined cantonal, district and communal level; and
- Swiss direct federal corporate income tax of 8.5% of profit after tax (roughly 7.8% of profit before tax).
Because cantonal profit tax is deductible for federal tax purposes (and vice versa), the combined effective corporate income tax rate on profit before tax is somewhat lower than the simple sum of the nominal rates. Independent corporate tax overviews quote a combined rate of approximately 12.66% for Appenzell Innerrhoden.
In a Swiss-wide comparison, this places Appenzell Innerrhoden among the lowest-tax cantons for companies, alongside Zug, Obwalden and Schwyz.
The actual effective rate for a specific company will depend on:
- The tax year (though rates have been stable at 6.0% since 2020);
- Participation relief for qualifying dividends and capital gains;
- Use of patent box and R&D additional deductions (subject to the relief cap);
- Any tax holidays or special status rulings (within the limits of post-STAF rules); and
- Allocation of profit between cantons and countries (permanent establishments, real estate).
Illustrative example (Appenzell)
Assume a standard capital company in Appenzell with:
- Taxable profit before tax: CHF 1,000,000;
- Taxable equity: CHF 2,000,000;
- No patent box, no R&D additional deduction, no special reliefs; and
- No participation relief (all income from operating activities).
Then, very roughly for a recent tax year:
- A combined corporate income tax burden of around CHF 125,000–130,000 (approx. 12.5–13.0% of profit before tax) is plausible, consistent with the quoted effective rate of approximately 12.66%.
- Capital tax at 0.5‰ of CHF 2,000,000 corresponds to CHF 1,000. Because profit tax is credited against capital tax, and the profit tax burden in this example is far higher than CHF 1,000, the separate capital tax does not increase the total burden – the company effectively pays only profit tax.
- In a low-profit or loss year, the profit tax may fall below the capital tax amount and the CHF 500 minimum capital tax can become the binding burden.
For binding calculations, use the official Appenzell Innerrhoden tax calculator (where available) or the cantonal tax administration’s published tables together with professional modelling.
The effective rates cited here are based on public corporate tax comparisons and cantonal investment promotion materials. They are intended as indicative benchmarks and do not replace a formal tax calculation, assessment notice or advance tax ruling.
Capital Tax, Minimum Tax & STAF Instruments
Capital tax & minimum capital tax
Appenzell Innerrhoden levies a capital tax on the equity of juristic persons. For capital companies and cooperatives, key features are:
- A statutory capital tax rate of 0.5‰ (0.05%) on taxable equity for capital companies and cooperatives.
- A minimum capital tax of CHF 500 per year for capital companies; the minimum applies where the capital-tax calculation would otherwise result in a lower amount.
- For other juristic persons and collective investment schemes with direct real estate holdings, equity below CHF 50,000 is not subject to capital tax.
- Profit tax is credited against capital tax, meaning that in profitable years capital tax is effectively absorbed by the higher profit tax; in low-profit or loss years, capital tax (and, if relevant, the minimum of CHF 500) ensures a base level of taxation.
The result is that capital tax in Appenzell Innerrhoden acts primarily as a minimum tax mechanism rather than as a separate significant burden for profitable companies.
Patent box, R&D deduction & relief cap (STAF)
In the context of STAF, Appenzell Innerrhoden introduced a set of internationally accepted instruments to accompany the reduction of ordinary rates:
- A patent box that allows a limited relief (around 10%) on qualifying patent income at the cantonal level – a comparatively modest patent box compared to cantons that allow up to 90% relief.
- An additional deduction for qualifying R&D expenses at the cantonal level, allowing effective R&D costs to be deducted at more than 100% of their accounting value, subject to detailed rules.
- A relief cap (e.g. at 50%) ensuring that the combination of patent box, R&D additional deductions and step-up / transitional relief cannot reduce the taxable profit below a specified fraction of the pre-relief profit.
- A modernised participation relief regime for qualifying shareholdings, reducing the effective tax burden on dividends and capital gains from participations.
Because ordinary rates are already low, these instruments mainly affect companies with substantial R&D and IP activities or those realising significant hidden reserves in a step-up context; for many SMEs, the main attraction remains the low ordinary rate of about 12.7% combined.
Modelling Tools & Calculators
To quantify the tax burden for a specific company in Appenzell Innerrhoden, combine official cantonal sources with independent comparison tools:
| Tool | What it does | How to use it for Appenzell Innerrhoden |
|---|---|---|
| “Steuern” brochure (Kanton Appenzell Innerrhoden) | Official economic promotion brochure summarising corporate tax parameters in Appenzell Innerrhoden: 6.0% profit tax, 0.5‰ capital tax, minimum capital tax, participation relief and qualitative information on STAF instruments and double taxation. | Use this brochure as a base reference for slides and location marketing, and to ensure that key figures such as 6.0% profit tax and 0.5‰ capital tax are aligned with the canton’s official communication. |
| Appenzell Innerrhoden tax administration (Gewinnsteuer & Kapitalsteuer pages) | Provides the legal profit tax rate for juristic persons (6.0% since 2020) and the capital tax rules, including minimum capital tax of CHF 500 and crediting of profit tax against capital tax. | Use the “Gewinnsteuer” and “Kapitalsteuer” pages to confirm current statutory rates and the interaction between profit tax and capital tax in technical memoranda or rulings. |
| Swiss corporate tax comparison tools | Provide combined effective corporate income tax rates (including federal, cantonal and communal taxes) for all cantons, including the figure of approximately 12.66% for Appenzell Innerrhoden. | Use them to benchmark Appenzell Innerrhoden against other cantons in board material, location studies and Pillar 2 analyses. |
| Federal guidance on taxation of juristic persons | Explains the general framework for corporate profit and capital tax in Switzerland, including the requirement that cantons levy capital tax and the typical interactions between profit and capital tax. | Use as background material when explaining Swiss corporate taxation (profit vs. capital tax, federal vs. cantonal) to foreign stakeholders considering Appenzell Innerrhoden. |
| TaxRep Appenzell Innerrhoden calculator (this hub) | Applies Appenzell Innerrhoden profit and capital tax parameters – 6.0% profit tax, 0.5‰ capital tax with CHF 500 minimum, profit-tax crediting, patent box, R&D deduction and relief cap – together with federal tax to your own profit and equity figures. | See the calculator page of this hub once the Appenzell Innerrhoden parameters are implemented. Use it for multi-year planning, location comparisons and Pillar 2 sensitivity analyses involving Appenzell Innerrhoden entities. |
Planning Considerations
| Theme | Rate impact | What to watch |
|---|---|---|
| Location choice within Appenzell Innerrhoden | Profit tax and capital tax are set at cantonal level without a tax factor mechanism, so intra-cantonal rate differences are limited compared with many other cantons. | Confirm any district- or municipality-specific surcharges or special arrangements (e.g. economic promotion agreements) with the cantonal authorities, but expect smaller variations than in cantons with wide communal factor ranges. |
| Capital structure & minimum capital tax | With a 0.5‰ rate and CHF 500 minimum capital tax, capital tax is modest for capital-intensive companies but can be proportionally more relevant for very small entities or in loss years. | Model multi-year profit and equity developments. Ensure that the crediting of profit tax against capital tax and the CHF 500 minimum are correctly reflected in internal calculations, especially when budgeting loss years or start-up phases. |
| Use of patent box & R&D deductions | Even though Appenzell Innerrhoden applies a relatively modest patent box relief (e.g. 10% reduction of qualifying income), the combination with R&D additional deductions and a low ordinary rate can still materially reduce the effective rate for R&D- and IP-intensive businesses. | Carefully document qualifying IP and R&D expenditure and consider advance rulings for significant claims. Monitor the relief cap to ensure that combined reliefs do not exceed the statutory maximum and that Pillar 2 implications are properly assessed. |
| Participation structures & holding functions | Participation relief and low ordinary rates make Appenzell Innerrhoden attractive for holding and mixed companies, especially in groups that are not subject to Pillar 2 top-up tax. | Verify that participations meet thresholds (typically ≥10% or CHF 1m fair value). Align financing and substance with international tax and transfer pricing requirements and consider double tax treaties for outbound income. |
| Pillar 2 and global minimum tax | With a combined effective corporate income tax rate of about 12.7%, Appenzell Innerrhoden sits below the 15% global minimum rate, so large groups with Appenzell Innerrhoden entities may face Pillar 2 top-up tax elsewhere. | Integrate Appenzell Innerrhoden entities into group-wide GloBE effective tax rate models. Consider whether to adjust the use of STAF incentives or profit allocation to manage Pillar 2 exposure, especially in combination with entities located in higher- tax jurisdictions. |
| Entities with ideal or charitable purposes | Juristic persons with ideal or charitable purposes may benefit from reduced profit tax and capital tax burdens or exemptions, subject to purpose and use-of-funds tests. | For associations and foundations, review statutes and actual activities for compliance with the requirements for tax-favoured status and ensure that profits and assets are used exclusively and irrevocably for the stated ideal purposes. |
FAQs
What is the corporate income tax rate in Appenzell Innerrhoden?
Appenzell Innerrhoden applies a flat profit tax rate of 6.0% for juristic persons at the combined cantonal, district and communal level. Together with Swiss direct federal corporate income tax (8.5% on profit after tax, roughly 7.8% on profit before tax), this results in a combined effective corporate income tax burden of around 12.66% on profit before tax for a standard company, according to independent corporate tax comparisons. The exact rate depends on profit level, reliefs and any special arrangements.
What is the capital tax rate for companies in Appenzell Innerrhoden?
The cantonal capital tax rate for capital companies and cooperatives in Appenzell Innerrhoden is 0.5‰ (0.05%) of taxable equity. Capital tax is subject to a minimum of CHF 500 per year for capital companies. Profit tax is credited against capital tax, so that capital tax primarily functions as a minimum tax when profit tax would otherwise be lower.
How does the minimum tax work?
Appenzell Innerrhoden does not have a separate minimum profit tax for companies, but the minimum capital tax of CHF 500 effectively ensures that a capital company pays at least this amount annually. If the capital-tax calculation based on 0.5‰ of equity gives a lower amount, or if profit tax credited against capital tax is below CHF 500, the company still pays the minimum capital tax. For other juristic persons, equity below CHF 50,000 is exempt from capital tax.
Does Appenzell Innerrhoden have a patent box and R&D additional deductions?
Yes. In connection with the STAF reform, Appenzell Innerrhoden introduced a patent box, a regime for additional deductions for qualifying R&D expenses and a relief cap that limits the combined effect of these incentives and other reliefs to a specified percentage of profit. The canton’s patent box is relatively modest compared with some other cantons (for example, with a relief of around 10% on qualifying income), reflecting a cautious use of STAF instruments on top of already low ordinary rates.
Are the same rates used for all companies?
The 6.0% profit tax rate and 0.5‰ capital tax rate apply to all juristic persons of the relevant type (e.g. capital companies and cooperatives), but the effective tax burden can vary depending on participation relief, use of patent box and R&D incentives, step-up / transitional provisions, loss carryforwards, allocation of profit between cantons and countries and any advance rulings. Associations, foundations and entities with ideal or charitable purposes can be subject to different rules or exemptions.
Where can I check the current Appenzell Innerrhoden rates?
The most reliable sources are the official Appenzell Innerrhoden tax administration website – particularly the pages on Gewinnsteuer and Kapitalsteuer for juristic persons – and the economic promotion brochure on taxes (Steuern), as well as Swiss-wide corporate tax comparisons by advisory firms. For important structuring, relocation or investment decisions, it is advisable to obtain written confirmations or advance tax rulings from the cantonal authorities.
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