Fribourg Capital Tax
Last updated: 15 Dec 2025
Fribourg Capital Tax — Equity Tax Rules
How capital tax works for companies in the Canton of Fribourg: who is subject to equity tax, how the taxable capital base is determined, the standard and reduced capital tax rates, the profit-tax crediting mechanism (profit tax imputed against capital tax), the minimum tax on gross receipts, and how capital tax interacts with corporate income tax.
Scope & Taxpayers
- Resident companies. Capital tax applies to companies with statutory seat or effective place of management in Fribourg (AG/SA, GmbH/Sàrl, cooperatives and other juristische Personen / personnes morales) on their equity allocable to the canton.
- Nonresident entities. Nonresident companies are subject to Fribourg capital tax on equity attributable to a permanent establishment in Fribourg and/or Fribourg-situs real estate and related business assets (allocation is key).
- Tax period and valuation. Capital tax is assessed annually. The starting point is the statutory balance sheet equity, adjusted for tax purposes (e.g., hidden equity where shareholder financing is excessive).
- Municipal layer. Communes levy their taxes as a percentage of the cantonal base tax. Your effective burden therefore depends on the commune coefficient.
Tax Base: Equity & Hidden Equity
For Fribourg capital tax, the taxable base is taxable equity (capital propre imposable / steuerbares Eigenkapital): share/paid-in capital and reserves (open), plus tax adjustments where relevant (including hidden equity).
| Component | Included? | Comment |
|---|---|---|
| Share / paid-in capital | Yes | Included for AG/SA and GmbH/Sàrl based on the registered paid-in amounts. |
| Open reserves | Yes | Legal reserves, voluntary reserves and retained earnings form part of taxable equity. |
| Hidden reserves / step-ups | Yes, in principle | Where step-ups are recorded (migrations/reorganisations) or assets are carried below tax values, taxable equity can increase. |
| Hidden equity (recharacterised debt) | Yes, if triggered | Excess shareholder loans can be reclassified as hidden equity under thin-capitalisation practice, increasing taxable equity. |
| Associations / foundations (other juristic persons) | Yes, with thresholds | For associations, foundations and other juristic persons, taxable equity generally follows “net assets” concepts; small equity amounts may be exempt below thresholds. |
In multi-canton or cross-border cases (branches/real estate), allocate equity consistently to Fribourg vs. other cantons/foreign jurisdictions, aligned with your profit allocation approach.
Rates, Reduced Rate & Minimum Tax
Capital tax rate (Fribourg)
Fribourg levies capital tax on taxable equity at a statutory base rate:
- Standard capital tax rate: 1‰ of taxable equity (0.10%).
Fribourg also provides a reduced capital tax rate for certain categories of equity (subject to definitions and documentation):
- Reduced rate: 0.1‰ on equity attributable to qualifying participation rights, certain IP rights (e.g., patent-related) and group loans.
Effective payable amounts depend on the commune coefficient and any church tax coefficients (where applicable for juristic persons). For quick modelling, use the official cantonal calculator.
- Fribourg official corporate tax calculator (juristic persons)
- Rates page of this hub
Profit-tax crediting & minimum tax on gross receipts
Fribourg coordinates profit tax and capital tax through a crediting mechanism:
- Profit tax imputed to capital tax. The profit tax due by companies is credited against capital tax, up to the amount of the capital tax. In practice, capital tax often functions as a minimum in low-profit years.
In addition, Fribourg levies an impôt minimal (minimum tax) on gross receipts for certain operating companies, if it exceeds the ordinary profit + capital tax:
- 0.25‰ on gross receipts from wholesale trade and manufacturing.
- 0.7‰ on other gross receipts.
- Only the portion of gross receipts exceeding CHF 500,000 per year is considered.
- Newly incorporated companies (not arising from transformations) are typically exempt from the minimum tax in the foundation year and the two following years.
Switzerland levies no federal capital tax. Capital tax is cantonal/communal only. In Fribourg, commune coefficients can materially change the effective burden.
Interaction with Profit Tax
Capital tax and corporate income tax are assessed together for juristic persons, but they use different bases: profit tax on taxable net profit and capital tax on taxable equity.
- Same return, separate computations. The corporate return includes both profit and equity schedules.
- Crediting drives outcomes. Because profit tax can be imputed to capital tax, capital tax often becomes relevant as a binding minimum in low-profit or loss years.
- Reduced-rate assets. Participation rights, qualifying IP and group loans can lower the capital-tax burden via the reduced rate.
- Minimum tax overlay. For operating companies with significant turnover, the gross-receipts minimum tax can be the binding charge in specific situations.
For the profit tax side, see the Fribourg corporate tax page and the calculator.
Planning Points & Typical Cases
| Theme | Capital tax angle (Fribourg) | Typical actions |
|---|---|---|
| Holdings & participations | Equity attributable to qualifying participation rights can be taxed at the reduced 0.1‰ rate; profit-tax participation relief affects dividends/gains. | Maintain participation documentation; reconcile equity to reduced-rate assets; consider rulings for large structures. |
| IP & patents | Certain IP (patent-related) can attract reduced capital tax; profit-tax tools (e.g., patent box) may also be relevant depending on facts. | Map IP rights and functions; support valuations; coordinate profit and capital planning. |
| Group loans & treasury | Group financing can benefit from reduced capital tax for qualifying group loans, but requires clear classification and documentation. | Document loan book and terms; align transfer pricing; model minimum-tax effects. |
| Turnover-heavy, low-margin businesses | The gross-receipts minimum tax can become binding even when profit is low. | Model the minimum tax by activity category; review revenue mapping; plan margins and structure with the combined system in mind. |
| Equity vs. shareholder debt | More equity increases the base; excessive shareholder loans can be recharacterised as hidden equity and increase the base anyway. | Thin-cap review; arm’s-length terms; governance for intercompany financing and cash pooling. |
Compliance Snapshot
Capital tax is assessed and collected together with corporate income tax for juristic persons. For procedural detail, see the Forms & deadlines page.
| Area | Key points |
|---|---|
| Return | Annual corporate tax return includes both profit and equity schedules, plus any schedules supporting reduced-rate asset categories and minimum-tax calculations. |
| Deadline | Typically aligned with the corporate filing deadline (often around six months after year-end; extensions generally available). |
| Documentation | Financial statements; equity reconciliation; participation list; group loan schedules (if applicable); IP/patent documentation (if applicable); turnover breakdown for minimum tax (if relevant). |
| Assessments & objections | Assessment covers profit, capital and any minimum-tax components. Objections should separate issues relating to profit base, equity base, reduced-rate classifications and minimum tax. |
FAQs
What is the standard capital tax rate in Fribourg?
Fribourg’s standard capital tax rate is 1‰ of taxable equity (0.10%). The effective payable amount depends on the commune coefficient.
Is there a reduced capital tax rate in Fribourg?
Yes. Fribourg applies a reduced rate of 0.1‰ for equity attributable to qualifying participation rights, certain patent-related rights and qualifying group loans (subject to definitions and documentation).
Do I always pay capital tax in Fribourg?
Not necessarily. Profit tax is generally credited against capital tax up to the amount of the capital tax. In many profitable years, this can mean capital tax is economically neutral, while in low-profit years capital tax can be binding.
What is the minimum tax (impôt minimal) in Fribourg?
For certain operating companies, Fribourg levies a minimum tax on gross receipts if it exceeds the ordinary profit + capital tax. Rates include 0.25‰ (wholesale/manufacturing) and 0.7‰ (other receipts), generally applying only on the portion of gross receipts exceeding CHF 500,000 per year.
How do I get an accurate estimate for my commune?
Use the official Fribourg corporate tax calculator and select the relevant commune/year. For multi-canton structures, ensure your equity allocation to Fribourg is consistent with profit allocation.
Get Fribourg capital & corporate tax help (Sesch TaxRep GmbH) Fribourg cantonal tax service