Grisons Corporate & Capital Tax
Last updated: 09 Dec 2025
Grisons (Graubünden) Corporate & Capital Tax — Business Tax Overview
How corporate income tax and capital tax work in the Canton of Grisons (Graubünden) for companies: who is taxed, what is taxed, how rates are built up (with combined profit tax levels in the mid-teens in many locations), where Grisons sits in the Swiss landscape, and where to dive deeper (profit tax, capital tax, rates, cases, calculator, and forms & deadlines).
Grisons at a Glance
Position in the Swiss tax landscape
Grisons is a mountain canton with a competitive mid-range corporate tax level:
- Ordinary companies in the cantonal capital Chur typically face a combined (cantonal/communal plus federal) corporate income tax rate in the mid-teens on profit before tax, depending on year, municipality and use of reliefs.
- Historically, Grisons’ maximum rate for regularly taxed companies is around the mid-teens on net profit, placing the canton in the front half of Swiss locations in terms of effective corporate tax burden.
- Capital tax on equity is levied at modest levels, and for many profitable companies the overall burden is dominated by profit tax.
- The canton combines tourism (e.g. Davos, St. Moritz), energy, industry and services, with multilingual regions (German, Romansh, Italian) and a pragmatic tax administration.
Key features for companies
| Tax types | Cantonal/communal profit tax, cantonal/communal capital tax, federal corporate income tax. |
| Taxpayers | Capital companies (AG, GmbH), cooperatives, certain foundations and associations. |
| Profit tax base | Taxable profit derived from statutory accounts with tax adjustments and STAF instruments. |
| Capital tax base | Equity (including reserves and hidden equity) attributable to Grisons, subject to reliefs and cantonal rules. |
| STAF tools | Participation relief, patent box, additional R&D deductions and related measures. |
Who Is Taxed & On What?
- Resident companies. Companies with their statutory seat or effective place of management in Grisons are subject to unlimited tax liability on their worldwide income and equity, with exemptions or credits for foreign permanent establishments and real estate under Swiss and treaty rules.
-
Nonresident entities. Nonresident companies are subject to
limited tax liability in Grisons on profit and equity attributable to:
- Permanent establishments in Grisons; and/or
- Grisons-situs real estate or business assets.
- Legal forms in scope. The rules in this hub primarily address juristische Personen (AG, GmbH, cooperatives). Partnerships and sole proprietors are taxed via personal income tax and are not the focus here.
- Tax period. For juristic persons, the tax period generally follows the financial year. Year-end changes or extended first years require coordination with the Grisons tax office (Steuerverwaltung Graubünden).
Corporate Income Tax vs. Capital Tax
Grisons, like other Swiss cantons, taxes companies both on their annual profit and on their equity. Understanding the distinction is key for planning relocations, investments and group structures in the canton.
| Aspect | Corporate income tax (profit tax) | Capital tax (equity tax) |
|---|---|---|
| Tax base | Taxable profit for the year (after adjustments, participation relief, STAF reliefs and loss offsets). | Equity attributable to Grisons (share capital, reserves, hidden equity) valued under cantonal rules. |
| Economic focus | How much the company earns in or allocated to Grisons. | How strongly the company is capitalised and where assets (especially real estate, participations and long-term assets) reside. |
| Key drivers | Business model, margins, transfer pricing, location of functions/risks, and use of patent box and R&D deductions. | Financing mix (equity vs debt), participations, IP, Grisons real estate and infrastructure or energy assets. |
| Interaction | Profit tax is calculated on taxable profit; STAF instruments can materially reduce the effective rate for qualifying companies. | Capital tax often operates as a minimum tax in low-profit or loss years; in profitable years, profit tax usually dominates the overall burden. |
| Where to read more | Grisons corporate tax | Grisons capital tax |
For many Grisons companies, the combined profit and capital tax burden is driven primarily by profit tax. But for holding structures, asset-rich businesses (tourism, energy, real estate) and early-stage entities, capital tax can still be a meaningful additional cost or binding minimum and should be modelled explicitly.
Indicative Rate Level & Competitiveness
Where do Grisons rates sit?
While exact figures depend on tax year, commune, profit level and use of reliefs, Grisons is typically viewed as:
- In the competitive mid-range of Swiss effective corporate tax rates, with combined profit tax (including the federal layer) generally in the mid-teens for standard operating companies in key locations such as Chur.
- More attractive than traditional high-tax cantons, but not at the very bottom of Swiss corporate tax rates; a robust option for operating businesses with substance in the Alpine and eastern regions.
- Capable of offering targeted solutions for holdings, IP and financing entities via STAF instruments, rulings and careful choice of commune.
For statutory parameters and trends over time, see the Rates page, which summarises simple rates, tax factors and minimum tax rules for Grisons.
Quick modelling
To get a first feel for the combined tax burden (cantonal, communal and federal) on your company’s profit and equity in Grisons:
- Use this hub’s Grisons tax calculator for an approximate estimate; and
- Cross-check with official cantonal or federal 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 Grisons tax office are usually the next step.
STAF, IP & Special Situations
Grisons has implemented the Swiss corporate tax reform (STAF) 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.
| Instrument | What it does | Where to look |
|---|---|---|
| Participation relief | Reduces the effective tax burden on qualifying dividends and capital gains from shareholdings in subsidiaries, significantly lowering profit tax for classic holding and group structures. | Explained in depth on the corporate tax page (participation income section). |
| Patent box | Allows qualifying IP income to be taxed at a reduced level, provided nexus and tracking conditions are met. This can make Grisons attractive for IP-oriented operating companies with real substance. | Particularly relevant for IP companies and R&D structures described in the cases section. |
| R&D deductions | Provide additional deductions (beyond normal expenses) for qualifying R&D expenditure, lowering the profit tax base and effective rate. | Discussed in both the corporate tax and cases pages. |
| Capital tax relief | Certain assets (e.g. participations, IP) may benefit from privileged treatment for capital tax, and profit tax paid may reduce the residual capital tax burden. This is particularly relevant for holding and financing structures in Grisons. | See capital tax and planning aspects on the rates page. |
These instruments are powerful but documentation-heavy. For material structures, Grisons 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 Grisons company (AG or GmbH), the recurring tax workflow looks roughly like this:
| Step | 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 with Grisons corporate and capital tax rules in mind. | Internal accounting, auditors, group tax. |
| 2. Tax return preparation | The Grisons corporate tax return is prepared, including profit-to-tax reconciliation, capital tax base and any STAF instruments (patent box, additional R&D deduction). | Forms & deadlines |
| 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. | Forms & deadlines |
| 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: corporate tax, capital tax. |
| 5. Planning & rulings | For restructurings, IP or financing changes, relocations into or out of Grisons or major investments, models are updated and rulings are prepared with Grisons and federal authorities. | Cases & Grisons Tax Service |
FAQs
Is Grisons a high- or low-tax canton for companies?
Grisons sits in the competitive mid-range of Swiss corporate tax cantons. It is not as low as the very cheapest cantons, but materially more attractive than traditional high-tax cantons. For many operating businesses with activities in the Alpine region or eastern Switzerland, it offers a balanced mix of rates, environment and administrative practice.
Do I always pay both profit tax and capital tax in Grisons?
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. Special regimes and 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 Grisons?
For routine annual filings, rulings are not usually needed. For structuring questions (holdings, IP, financing, relocations, major restructurings or large investments), rulings are common and provide valuable certainty, particularly where several cantons or countries are involved.
Can I manage Grisons corporate tax from abroad?
Many groups manage Swiss corporate tax centrally and work with local advisors for Grisons 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 Grisons entities.
Where do I start if I am considering a move to Grisons?
A typical sequence is: (1) high-level rate comparison and effective tax modelling for Grisons vs. alternative cantons; (2) review of substance, functions and people; (3) structuring concept (legal form, holding / IP / finance set-up in or via Grisons); and (4) pre-filing discussions and rulings with the Grisons tax authorities. The Grisons Tax Service is designed to support exactly this path.
Discuss your Grisons corporate tax position (Sesch TaxRep GmbH) Contact