Swiss Stamp Duties & Securities Transfer Tax
Swiss Stamp Duties & Securities Transfer Tax
Switzerland levies specific federal stamp duties on the issuance and transfer of certain financial instruments. These include the stamp issuance duty, the securities transfer tax, and the stamp duty on insurance premiums. The scope and rates are defined at the federal level and apply in addition to profit and capital taxes. Understanding when these duties apply is essential for financial institutions, corporations, and investors.
1. Stamp Issuance Duty
The issuance of Swiss equity securities is subject to a federal stamp duty:
- Rate: 1% of the contribution value.
- Applies to incorporations, capital increases, and contributions without issuance of shares.
- Exemption: The first CHF 1 million of equity raised is exempt.
2. Securities Transfer Tax
The transfer of taxable securities is subject to stamp duty if a Swiss securities dealer is involved as a party or intermediary.
- Rate: 0.15% on Swiss securities, 0.3% on foreign securities.
- Taxable persons: Swiss securities dealers (including banks) and, in some cases, large holding companies or pension funds qualifying as dealers.
- Scope: Applies to shares, bonds, fund units, and similar instruments; derivatives are generally excluded.
3. Stamp Duty on Insurance Premiums
Insurance premiums paid to Swiss insurers may be subject to federal stamp duty:
- General rate: 5% of the premium.
- Exemptions: Life insurance and certain reinsurance premiums.
4. Exemptions & Relief
- Intragroup transfers of securities may be exempt under specific conditions.
- New issues of bonds and money market instruments are exempt from issuance duty.
- Cross-border relief may apply under bilateral agreements or specific rulings.
5. Compliance & Practical Aspects
- Stamp duties are generally reported and remitted by securities dealers or insurers.
- Corporates raising equity must declare and pay issuance duty to the Swiss Federal Tax Administration (FTA).
- Proper documentation is crucial to benefit from exemptions and avoid penalties.