1. Inheritance and gift tax reform
Increase in tax exemption thresholds for direct descendants

  • Estates: increase from CHF 250,000 to CHF 1,000,000
  • Annual donations: increase from CHF 50,000 to CHF 300,000

2. Business transfer by succession or gift to children
Admission of a 50% allowance from a holding rate of 25%, compared with the current thresholds:

  • 33% for passenger companies
  • 40% for joint-stock companies

3. Reduction in cantonal income tax -> by 2027
Additional reduction of 0.5% in the basic cantonal tax rate to reach a total rate of 4% on January 1, 2025, compared with 3.5% in 2024.

An additional 1% reduction in the basic cantonal tax rate to reach a total rate of 5% on January 1, 2026, compared with 4% in 2025.

An additional 2% reduction in the basic cantonal tax rate to reach a total rate of 7% on January 1, 2027, compared with 5% in 2026.

4. Modification of the Tax Shield
Revision of the tax shield mechanism to return to the terms in force until tax year 2021.

=> This amendment would come into force on July 1, 2025, provided that the popular initiative “Lower taxes for all” is not accepted in the referenda scheduled between now and June 30, 2025. In this case, it would apply to all tax assessments still open from the 2022 tax period onwards.

5. Adaptation of the ACI Directive on the valuation of unlisted securities (RETIF)
Executive shareholders who are active in their company and hold the company’s share capital in their private assets may, on request and subject to conditions, benefit from a privileged valuation of their securities for wealth tax purposes. Planned changes to the IFA Directive (effective January 1, 2022) :

  • Raising the ownership threshold for micro-businesses (5 to 10 employees) from 25% to 10% to qualify for RETIF.
  • Deletion of the content requirements listed in the Directive on the material requirements for the content of shareholder agreements.
  • Clarification of the notion of “compliant salary”: the minimum salary ratio applicable to the liberal professions would be lowered from 70% to 50% of profit, plus the salary of the managing shareholder.


Tax changes effective January 1, 2025

1. Corporate income tax rates

  • Profits of less than CHF 10 million: basic tax rate maintained at 3.33%.
  • Profits in excess of CHF 10 m: basic tax rate of 3.33% up to CHF 10 m, with a rate of 3.75% for the portion exceeding this threshold.

2. Maintenance of the cantonal tax coefficient: the coefficient remains at 155% for 2025 and for the years 2026 to 2028.

3. Fiscal interest rate trends

  • Interest: 0325% in 2024 -> 0.3% from 2025
  • Interest on arrears: 4.75% in 2024 -> 4.5% from 2025
  • Compensatory interest: 0.325% in 2024 -> 0.3% from 2025
Nathalie Grangier
Certified Fiduciary Expert, Director

This publication contains general information and is not a substitute for detailed research or expert advice. No liability can be accepted for its content. For specific questions, please contact the author.