St. Gallen Capital Tax
Last updated: 09 Dec 2025
St. Gallen Capital Tax — Equity Tax Rules
How capital tax works for companies in the Canton of St. Gallen: who is subject to equity tax, how the taxable capital base is determined, how the cantonal rate and minimum tax operate, which reliefs exist for holding and mixed companies, 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 St. Gallen (AG, GmbH, cooperatives and other juristische Personen), on their equity allocable to the canton.
- Nonresident entities. Nonresident companies with a permanent establishment or St. Gallen–situs real estate are subject to capital tax on the equity attributable to those St. Gallen assets and operations.
- Tax period and valuation date. Capital tax is assessed annually, typically based on equity at the beginning or end of the business year, as defined in St. Gallen tax law and practice. Book values are the starting point, but hidden equity may be added or adjustments made where accounts do not reflect tax values.
- Legal form. The rules on this page focus on capital companies and cooperatives. Associations, foundations and entities with ideal or charitable purpose may benefit from exemptions or separate capital tax rules.
Tax Base: Equity & Hidden Equity
For St. Gallen capital tax, the taxable base is equity as defined in the cantonal tax act (share capital and reserves, open and hidden), subject to specific adjustments and reliefs.
| Component | Included? | Comment |
|---|---|---|
| Share/paid-in capital | Yes | Fully included in the capital tax base for AGs and GmbHs, based on the registered commercial register amount. |
| Open reserves | Yes | Legal reserves, voluntary reserves and retained earnings form part of taxable equity. |
| Hidden reserves (including goodwill) | Yes, in principle | To the extent that assets are carried below tax values or significant hidden reserves exist, St. Gallen practice can require adjustment, particularly in restructurings, migrations or transactions with related parties. |
| Revaluation reserves | Yes | Revaluation reserves and step-up amounts become part of equity and hence the capital tax base once recorded. |
| Non-business assets | Yes | Private or non-business assets held within the company are fully subject to capital tax and may impact profit tax as well (e.g. deemed income). |
| Hybrid instruments & shareholder loans | Partially | Excessive shareholder loans may be recharacterised as hidden equity under thin-capitalisation rules, increasing the capital tax base. |
| Participations & IP | Yes, but often relieved | Qualifying participations and, in some cases, IP can benefit from reduced capital tax rates or capital tax base relief under STAF-related measures. |
The precise capital tax base is determined under Art. 96 ff. of the St. Gallen tax act and cantonal practice (St. Galler Steuerbuch). For groups, allocation of equity between St. Gallen and other cantons or foreign jurisdictions is a critical step and should follow consistent allocation keys.
Rates, Minimum Tax & Special Statuses
Standard rate & minimum tax
For ordinary capital companies and cooperatives, St. Gallen applies a simple capital tax rate (per-mille rate) to the taxable equity. This simple rate is then multiplied by the applicable overall tax factor (Steuerfuss) to arrive at the effective cantonal/communal capital tax.
In addition, St. Gallen levies a minimum tax. If the combined simple profit and capital tax for a company does not reach the statutory minimum amount, the minimum tax applies instead. The minimum is multiplied by the tax factor, so the effective minimum burden increases in line with the cantonal tax factor.
The effective burden can vary over time as the overall tax factor is adjusted. For current figures by tax year, see:
- The official St. Gallen tax calculator for companies , and
- the Rates page of this hub.
Holding, domiciliary & mixed companies
St. Gallen grants reduced capital tax rates or special rules for companies with specific functions, in particular:
- Holding companies. Significantly reduced per-mille rate on equity and a minimum capital tax threshold, combined with profit tax privileges (subject to current STAF implementation and transitional rules).
- Domiciliary companies. Reduced capital tax rate; capital tax often functions as a minimum tax, with profit tax credits applied.
- Mixed companies. Capital tax applied to the Swiss-allocated equity portion, combined with ordinary or partially relieved profit tax on Swiss-source income.
The detailed conditions and rates for these statuses are set out in the St. Gallen tax act and cantonal guidance, and have evolved with the phasing-out of traditional regimes under STAF. In practice, advance tax rulings are used to confirm status and the interaction of profit and capital tax.
Interaction with Profit Tax
Capital tax in St. Gallen is closely coordinated with corporate income tax. A few key points:
- Same return, separate bases. Profit tax is levied on taxable income; capital tax is levied on equity. Both are calculated using the same corporate tax return for juristic persons, but with different schedules.
- Minimum tax mechanism. If the sum of simple profit tax and simple capital tax is below the statutory minimum amount, the minimum tax applies, ensuring a base level of cantonal revenue even for low-profit or loss-making companies.
- Profit tax credits. For certain special-status companies, St. Gallen credits profit tax against capital tax, effectively making capital tax function as a minimum tax in profitable years.
- Planning tension. Higher equity reduces financing risk and thin-cap exposure for profit tax, but increases capital tax. Optimising the mix of equity and debt is therefore a combined profit-and-capital tax question.
- STAF interaction. Reductions in the capital tax base for qualifying participations or IP (where applicable) can materially change the balance between profit and capital tax burden for holding and IP-rich structures.
For the profit tax side, see the St. Gallen corporate tax page and the combined tax calculator.
Planning Points & Typical Cases
| Theme | Capital tax angle | Typical actions |
|---|---|---|
| Financing structure | More equity means higher capital tax but less thin-cap risk, while high shareholder debt can be challenged and reclassified as hidden equity. | Review intra-group financing; align with Swiss thin-capitalisation practice; document arm’s-length interest rates and security. |
| Holding structures | Qualifying holding companies may enjoy reduced capital tax rates and special profit tax treatment, making capital location a key design question. | Assess whether holding criteria are met; consider centralising holdings in St. Gallen; obtain rulings to secure treatment. |
| IP & R&D | IP-rich companies may face higher equity and hence capital tax, but can use STAF instruments (e.g. patent box, R&D super-deduction, capital tax relief). | Map IP assets and functions; ensure robust valuation and cost tracking; coordinate profit and capital tax optimisation. |
| Real estate & non-core assets | Real estate and non-core assets often carry significant equity and hidden reserves, increasing capital tax and affecting allocation between cantons. | Consider spin-offs or separate property companies; align asset location with business strategy and tax burden; review allocation keys. |
| Restructurings & migrations | Changes of seat, mergers or de-mergers may crystallise hidden reserves or trigger special capital tax rules and minimum tax effects. | Plan transactions early; prepare pro-forma balance sheets and allocation; seek rulings from St. Gallen and federal tax authorities. |
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 for juristic persons, typically prepared using eTaxes-Unternehmen, includes both profit and capital tax sections. |
| Deadline | Same filing deadline as for profit tax (usually six months after year-end, with possible extensions). The capital tax base must be documented for the same period. |
| Documentation | Balance sheet; equity reconciliation; details of participations, IP and major revaluations; analysis of hidden equity and shareholder loans where relevant. |
| Assessments & objections | A single assessment covers profit and capital tax. Objections must clearly distinguish issues relating to the profit tax base and the capital tax base. |
FAQs
What is taxed under St. Gallen capital tax?
St. Gallen capital tax is levied on the company’s equity attributable to the canton: share capital, open reserves, retained earnings and, where relevant, hidden equity. Certain assets such as participations and IP may benefit from relief, but they generally form part of the starting equity base.
How is the capital tax rate determined?
The canton sets a simple capital tax rate (per-mille of equity). This rate is then multiplied by the cantonal tax factor (Steuerfuss) that also applies for profit tax. The effective burden therefore reflects both the statutory rate and the current tax factor for the relevant year.
Is there a minimum capital tax in St. Gallen?
Yes. If the combined simple profit and capital tax does not reach a minimum threshold, a minimum tax applies, which is then multiplied by the tax factor. This ensures that even loss-making or low-profit companies contribute a basic amount of tax.
Do holding companies pay capital tax in St. Gallen?
Holding companies are generally subject to capital tax but often at a significantly reduced per-mille rate and with a defined minimum tax. Traditional holding regimes have been adapted in the context of STAF, and many structures rely on rulings to confirm the current capital tax treatment.
Can capital tax be reduced through planning?
Within legal limits, yes. Typical levers include optimising equity vs. debt, managing the location and structure of holdings and IP, and making use of STAF reliefs and reduced rates for qualifying companies. However, any planning must be consistent with substance, transfer pricing and Swiss anti-avoidance practice.
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