Nonresidents with real estate or business assets located in Geneva are subject to limited Swiss tax liability. This includes wealth tax on Swiss-situs assets, income tax on related income, and potential withholding or double-tax relief depending on treaties.

This page explains the Geneva-specific framework for nonresident wealth taxation in 2025, including allocation, deductions, and filing requirements.

1. Scope of Limited Tax Liability

A nonresident is liable to Geneva wealth tax only on assets economically connected to the canton, including:

• Real estate situated in Geneva
• Permanent establishments or branches in Geneva
• Business assets physically or economically tied to Geneva

Movable assets located abroad (cash, securities, foreign real estate) remain outside the Geneva wealth tax base.

2. Valuation Basis

Assets are valued in the same way as for residents:

• Real estate at the official valeur fiscale
• Business assets at book or market value (consistent with the practitioner method)

These values form the Swiss-situs wealth base for determining limited tax liability.

3. Debt Allocation

Nonresidents may deduct debt that is economically connected to their Geneva assets — typically mortgages or business loans directly funding those assets. Other unrelated personal debts (e.g. consumer loans) are not deductible.

• Only debt with a clear link to the taxable Geneva property or business counts.
• Documentation (loan agreements, mortgage certificates) must substantiate the link.
• Interest is deductible for income tax purposes to the extent it relates to Geneva income.

4. Allowances & Exemptions

Unlike residents, nonresidents generally do not benefit from personal allowances (e.g. married or children’s exemptions). Only the asset-specific exemptions, such as pension assets or exempt household effects within the property, may apply.

5. Double Tax Treaties

Switzerland’s double tax treaties (DTTs) generally assign taxing rights on immovable property to the state of location. Therefore, Geneva retains full taxing rights on Geneva real estate owned by nonresidents.

However, the DTT may require the taxpayer’s residence country to grant relief (exemption or credit) for Swiss tax paid. Income and wealth are often considered together in treaty calculations.

6. Swiss Tax Representative

Nonresidents must typically appoint a Swiss correspondence address or tax representative in Geneva. This ensures proper delivery of notices and handling of assessments and payments.

• Advisors or trustees in Switzerland can act as official representatives.
• Geneva tax authorities communicate primarily in French; representation simplifies compliance.

7. Filing & Payment Process

Nonresidents file a limited return for Swiss-situs income and wealth. The same electronic or paper forms apply, but the return covers only the Geneva assets and linked liabilities.

• Declare the valeur fiscale or business asset values as at 31 December.
• Attach mortgage or loan evidence where applicable.
• Use Geneva’s e-filing portal or submit through your appointed representative.

8. Illustrative Example — Nonresident Property Owner

Profile: Resident of France owning an apartment in Geneva.

• Valeur fiscale: CHF 950,000
• Mortgage balance (31 Dec): CHF 600,000
• Commune coefficient: 0.40

Taxable Swiss-situs wealth: CHF 350,000 → Cantonal base ≈ CHF 2,000 × (1 + 0.40) → Total ≈ CHF 2,800.

9. Exiting Swiss Tax Liability

On disposal of Geneva property or cessation of business activity, the taxpayer must file a final limited return. This closes the local wealth tax account and ensures the refund or final settlement of provisional payments.

10. Planning Considerations for Nonresidents

• Evaluate ownership structures (direct vs. through company or trust) for cross-border estate and reporting implications.
• Review loan allocation and debt evidence annually.
• Confirm valuation updates with Geneva’s valeur fiscale adjustments.
• Ensure communication channels via a Swiss representative to avoid missed deadlines.