Lucerne Corporate Income Tax
Last updated: 13 Dec 2025
Lucerne Corporate Income Tax — Profit Tax Rules
How corporate income tax works in the Canton of Lucerne: who is subject to profit tax, how the tax base is determined from accounting profit, how cantonal, communal and federal components interact, and what to know about participation relief, Lucerne STAF measures and loss carryforwards.
Scope & Taxpayers
- Resident companies. Companies with statutory seat or effective place of management in Lucerne are subject to unlimited tax liability on their worldwide income, subject to relief for foreign permanent establishments and immovable property under double tax treaties and intercantonal rules.
- Nonresident entities. Nonresident companies are limited tax liable in Lucerne if they have local business operations, a permanent establishment, or Lucerne–situs real estate. Only the profits attributable to the Lucerne nexus are taxed.
- Juristic persons only. The corporate income tax described here applies to juristische Personen (AG, GmbH, cooperative, certain foundations and associations). Partnerships and sole proprietors are taxed at shareholder/owner level under personal income tax.
- Tax period. The profit tax period for juristic persons generally follows the financial year. A change of year-end or an extended first business year must be coordinated with the Lucerne tax office.
Tax Base: From Accounting Profit to Taxable Profit
Lucerne corporate income tax is levied on the company’s taxable profit, determined by starting from statutory financial statements (usually Swiss GAAP / OR, occasionally Swiss GAAP FER or IFRS for groups) and then making tax adjustments.
| Step | Description | Typical adjustments |
|---|---|---|
| 1. Accounting profit | Profit after tax per statutory financial statements for the relevant business year. | Profit as approved by the shareholders’ meeting, before appropriation of retained earnings. |
| 2. Add-backs | Non-deductible or partially deductible expenses are added back to profit. | Hidden profit distributions; excessive interest or royalties to related parties; non-business expenses; penalties; corporate income tax itself; certain provisions and value adjustments that are not commercially justified. |
| 3. Deductions | Items that are tax deductible but not expensed, or expensed differently, are deducted. | Tax-allowed depreciation that exceeds accounting depreciation (within limits); specific provisions; participation relief; Lucerne STAF instruments such as the patent box and, where activated in future, an additional R&D deduction. |
| 4. Allocation & exemptions | Profits allocable to other cantons or foreign permanent establishments are exempt in Lucerne under intercantonal and treaty rules. | Profit/loss attribution keys; separate determination of foreign PE income; treaty exemptions or credit methods. |
| 5. Taxable profit | Result after adjustments, before loss carryforwards and special reliefs. | Loss carryforwards of up to 7 years can be offset against current-year taxable profit (subject to general Swiss rules). |
The Lucerne tax book (Luzerner Steuerbuch) and cantonal practice notes provide detailed guidance on depreciation, provisions, hidden equity, participation relief and other adjustments relevant for the tax base. In practice, a clear reconciliation from accounting profit to taxable profit is expected as part of the Lucerne corporate tax return.
Rates & Effective Burden
Cantonal & communal profit tax
Lucerne applies a profit tax on net income at cantonal level, combined with communal multipliers. For standard capital companies and cooperatives, the canton levies a proportional profit tax, and each commune applies its own multiplier on the cantonal tax.
This results in a combined cantonal/communal profit tax that varies by municipality. In recent comparisons, effective profit tax burdens for capital companies (including federal tax, before church tax) are roughly:
- around 11.9% in the city of Lucerne; and
- around 11.1% in Meggen, one of the lowest corporate tax burdens in Switzerland.
The Steuergesetzrevision 2025 and related measures aim to keep Lucerne competitive for businesses, alongside instruments such as the patent box and capital tax adjustments.
For up-to-date Lucerne profit tax burdens by location, see the Rates page and the official Lucerne tax calculator for companies .
Federal corporate income tax
In addition to cantonal/communal profit tax, companies pay Swiss direct federal corporate income tax at a flat rate of 8.5% on profit after tax. Because federal tax itself is deductible, this corresponds to an effective rate of about 7.8% on profit before tax.
The combined effective corporate income tax rate for a Lucerne company is therefore the sum of:
- Cantonal/communal profit tax (based on the cantonal rate and the communal multiplier); and
- Direct federal corporate income tax.
The Lucerne tax calculator on this hub allows you to model combined cantonal, communal and federal profit tax for a given level of taxable profit and municipality.
Participation Relief & STAF Measures
Lucerne follows federal rules for participation relief and has implemented STAF (Swiss corporate tax reform and AHV financing) measures at cantonal level, including a patent box and the legal basis for an additional R&D deduction. Lucerne does not apply a notional interest deduction on equity.
| Mechanism | Overview | Typical planning aspects |
|---|---|---|
| Participation relief | Qualifying dividends and capital gains from shareholdings in subsidiaries are effectively subject to reduced taxation via a deduction calculated on the basis of net participation income relative to total profit (federal and Lucerne rules). | Minimum shareholding thresholds (e.g. 10% or CHF 1m market value); holding period; treatment of write-downs and liquidation proceeds; interaction with foreign withholding tax, treaty relief and Lucerne allocation rules. |
| Patent box | Income from qualifying intellectual property (in particular patents and comparable rights) can benefit from a reduced Lucerne profit tax base under patent box rules, subject to OECD nexus requirements and tracking of R&D expenditure. Lucerne has increased the patent box relief to up to 90% of qualifying income, combined with an overall relief cap at cantonal level. | Segregation of IP income and expenses; modelling the impact of the 90% relief and Lucerne’s relief cap; coordination between patent box calculations and group transfer pricing; interaction with global minimum tax (Pillar 2). |
| R&D super-deduction | Swiss law allows cantons to grant an additional deduction of up to 50% on qualifying R&D expenditure. Lucerne has created a legal basis to introduce such an R&D super-deduction but has so far not activated it in practice. Future ordinances could enable this instrument for innovative companies. | Monitoring Lucerne’s legislative developments; assessing potential benefit of an R&D deduction if introduced; aligning tax treatment with internal cost accounting and transfer pricing; documenting qualifying R&D activities in Switzerland. |
| Notional interest deduction (NID) | Unlike some high-tax cantons that could in theory introduce a notional interest deduction on equity, Lucerne has not implemented a cantonal NID, partly because of its already low profit tax burden. | For Lucerne entities, financing optimisation focuses on traditional debt/equity structuring, thin-capitalisation limits, and the interaction with participation relief and patent box regimes rather than NID planning. |
The combined relief from participation deduction, patent box and any future R&D super-deduction is subject to a maximum relief cap at cantonal level. In Lucerne, the entlastungsbegrenzung has been set at up to 70%, ensuring that at least a minimum portion of the underlying profit remains taxable at ordinary rates. For material structures, modelling and advance tax rulings are common.
Losses, Groups & Permanent Establishments
- Loss carryforwards. Tax losses can generally be carried forward for up to 7 years and offset against future taxable profits in Lucerne, within the standard Swiss framework. Loss carryback is not available.
- Group situation. Switzerland has no fiscal unity or tax consolidation for ordinary corporate income tax. Each Lucerne legal entity files its own return; group effects are managed via financing, transfer pricing, participation relief, and the use of patent box and other STAF instruments where relevant.
- Intercantonal allocation. Where a company has operations, real estate or permanent establishments in several cantons, profit and capital are allocated using generally accepted keys (e.g. payroll, assets, turnover) based on Lucerne practice and federal jurisprudence.
- Foreign permanent establishments. Under many treaties, profits attributable to foreign permanent establishments are exempt in Switzerland with progression. Accurate attribution of profits and capital is essential to support the exemption at Lucerne and federal level.
- Restructurings. Mergers, de-mergers, contributions in kind and migrations of seat can be tax neutral if Swiss conditions are met (continuity of business, carryover of hidden reserves, adequate consideration, etc.). Rulings are frequently used to secure treatment for Lucerne and federal purposes, especially where several cantons or countries are involved.
Interaction with Capital Tax
Corporate income tax and capital tax are closely linked in Lucerne. Profit tax is levied annually on taxable income, while capital tax is levied on the company’s equity. Both are assessed based on the same tax return for juristic persons.
- Lucerne has adjusted its capital tax regime in recent reforms, with a view to keeping the overall burden attractive while preserving revenue. The effective capital tax rate (including communal shares) is modest in an inter-cantonal comparison, particularly in municipalities such as Meggen.
- Higher equity increases capital tax, but may reduce thin-cap risks and support participation structures and IP-heavy business models that benefit from the patent box.
- For details on rates, reductions for participations and IP, and examples of combined profit and capital tax burdens, see the Lucerne capital tax page and the combined tax calculator.
Compliance Snapshot
This guide focuses on the substantive rules for corporate income tax in Lucerne. For procedural aspects — who files, which forms to use and which deadlines apply — see the dedicated Forms & deadlines page.
| Area | Key points |
|---|---|
| Filing | Annual corporate tax return for juristic persons, typically using the Lucerne tax return software and online tools; profit tax and capital tax are assessed together. Electronic filing is standard, with signed confirmations where required. |
| Deadline | Ordinarily around six months after year-end; extensions are commonly available on request (via Lucerne’s online extension tools within a standard window; beyond that by special request or via advisers). |
| Documentation | Signed financial statements; profit-to-tax reconciliation; schedules for participation relief and patent box; documentation for any future R&D deduction; transfer pricing documentation where relevant; intercantonal and international allocation workings. |
| Assessments & objections | Combined assessments for cantonal, communal and federal tax; objection rights and deadlines set out in the assessment notice. For complex cases, structured responses and, where appropriate, follow-up discussions with the Lucerne tax administration are common. |
FAQs
How high is the corporate income tax rate in Lucerne?
Lucerne applies a proportional cantonal profit tax with communal multipliers, plus federal corporate income tax at 8.5% on profit after tax (about 7.8% on profit before tax). In recent overviews, the combined effective rate (cantonal/communal plus federal, before church tax) is typically in the low double digits: around 11.9% in the city of Lucerne and somewhat lower (around 11.1%) in certain nearby municipalities such as Meggen. The exact burden depends on the commune, year and use of reliefs; see the Rates page and the Lucerne company tax calculator for concrete examples.
What is the difference between profit tax and capital tax?
Profit tax is charged on the company’s taxable income for the year, while capital tax is charged on the company’s equity (share capital, reserves and hidden equity) at the end of the year. Both are levied annually and assessed together, but they operate on different tax bases and rates. In Lucerne, profit tax tends to dominate for profitable operating companies, while capital tax becomes relatively more important for holding, treasury and low-profit entities.
Are dividends from subsidiaries fully taxed in Lucerne?
Qualifying participations can benefit from participation relief at federal and cantonal level. This mechanism reduces the effective tax burden on net participation income (dividends and certain capital gains) based on a formula comparing participation income to total profit. Where the conditions are met, the effective Lucerne and federal tax on qualifying dividends can be reduced significantly and in practice often to a low single-digit effective rate.
How are losses treated for Lucerne corporate income tax?
Tax losses can generally be carried forward for up to seven years and offset against future taxable profits. There is no loss carryback. In restructurings or changes of ownership, special Swiss rules may limit the use of losses; advance tax rulings are often used where material loss carryforwards are involved and Lucerne is a key canton in the group structure.
Can I get a ruling on a planned structure or transaction in Lucerne?
Yes. Lucerne, like other Swiss cantons, offers advance tax rulings. These are commonly used for holding and financing structures, IP arrangements, application of the patent box, reorganisations and relocations. A well-prepared ruling request can provide valuable certainty on the corporate income tax treatment and its interaction with capital tax and federal tax.
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