INDIVIDUAL TAXATION

Non-residents are taxed on Swiss-sourced income. Taxation occurs at the federal, cantonal and municipal levels. Spouses are taxed together. Investment income of a minor child is included in his parents’ income but his earned income is taxed separately.

INCOME TAX

Income from different sources are aggregated and taxed at the federal, cantonal and municipal levels. Different rates apply for married taxpayers (including those widowed, divorced, or single and supporting children or destitute persons) and unmarried taxpayers. Non-residents are not entitled to any personal deductions and allowances.

Federal Income Tax

Taxable income is generally computed as the aggregate of all kinds of income, less allowable deductions. The following tax rates apply for 2008:

Cantonal Income Tax

Cantons levy their own tax on income, and the tax rates vary from canton to canton. Just like the federal income tax, the cantonal income tax has progressive rates and is different for married couples and unmarried individuals.

The cantonal tax rates of Geneva are calculated based on a complex formula. The following is a simplified summary containing only selected tax brackets to give an indication of the basic cantonal tax rates in Geneva.

Municipal Income Tax

Municipalities also levy their own taxes on income. The municipal income taxes are generally similar to the cantonal income tax laws. The local authorities also determine their own coefficient, and they are levied in accordance with the cantonal income taxes.

RENTAL INCOME
Rental income in Switzerland is taxable at the federal, cantonal and municipal levels. Administration costs invoiced by third persons, necessary maintenance and improvement costs, as well as interest payments in respect of loans used to acquire income, are deductible from the taxable amount. The rates of the federal, cantonal and municipal income taxes are then applied. Since the cantonal and municipal income taxes are imposed on rental income, the total tax liability varies according to the location of the property.

CAPITAL GAINS
At the federal level, gains from the sale of private property are not taxable, and gains from the sale of business property are taxed as income. At the cantonal and municipal level, a real estate gains tax is imposed on the sale of both private and business property.

The rates for capital gains are usually progressive and the longer the property is owned, the lower the taxes. A shorter owning period would require a surcharge and both cantonal and municipal levels are applicable. The following are the cantonal rules for the disposal of immovable property:

• The standard rate is applicable after the holding period of four to five years. The top burden usually ranges from 25% to 50%.
• Tax is gradually reduced after exceeding the four to five years of ownership. The maximum relief allowed is 50% to 70% of the payable tax.
• A surcharge of up to 50% of the normal tax may be imposed on short term gains i.e. properties sold within the first four or five years.

Two systems are used to compute for taxable capital gains, the Zurich system and the St. Gallen System. The two systems are highly similar, since the computation for the taxable gains is selling price less acquisition costs and improvement costs for both systems. Their main difference lies in the computation for capital gains on business property. The Zurich system basically applies the same formula to business property as private property, and subjects recaptured depreciation to income tax, while the St. Gallen System subjects all capital gains from business and private property fully to income tax.

PROPERTY TAXATION

Wealth Taxes

Annual wealth taxes are levied at the cantonal level. Individuals pay taxes on enterprise assets and real estate situated in Switzerland. The tax payable varies from canton to canton. The assets are valued at their market value. Personal debts, mortgages, bank loans and overdrafts are deductible, as well as certain personal deductions and allowances from the taxable base, depending on the canton.

Property Taxes

Many municipalities and some cantons impose real property taxes on real estate located in Switzerland. The rates usually range from 0.05% to 0.3%, levied on the value of the property. The rates and the coefficient vary from canton to canton.

CORPORATE TAXATION

INCOME TAX

Corporate income is taxable at the federal, cantonal and municipal levels. Federal income tax is imposed at a flat rate of 8.5%. The cantonal income tax rates, as well as the municipal rates, vary depending on the canton and municipality the company is liable to pay taxes in.

CAPITAL GAINS
Capital gains on the sale of real estate property are taxable at the federal and cantonal levels. At the federal level, the gains are generally included in the taxable income. At the cantonal level, cantons use either the Zurich system or the St. Gallen System. Under the Zurich system, a separate real estate gains tax is levied on capital gains, while under the St. Gallen System, capital gains are included in corporate income tax.