Taxes
Contractual investment funds, SICAVs, and limited partnerships for collective investment are fiscally transparent, i.e. they are not subject to tax in their own right (with the exception of those that directly own real estate). Their assets and income are taxed exclusively and directly through the individual investors based on the rules in place in each investor’s tax domicile.
In principle, Swiss law makes no distinction between investments in Swiss and foreign collective investment schemes for the purposes of wealth and income tax. In both cases, investments are subject to wealth tax, and income is subject to income tax, regardless of whether it is distributed or reinvested. Capital gains, meanwhile, are not taxed, provided they are reported separately or paid out with a separate coupon. The specialist information factsheet “Collective investment schemes and taxes” explains the key tax rules from the point of view of investors, collective investment schemes, and fund providers.
The following list is broken down into three 'levels'
- investment fund (portfolio and application of income)
- investor
- fund provider
and gives a summary of the most important laws and ordinances as well as circulars and guidelines and directives issued by the Swiss Federal Tax Administration (FTA) that must be observed in the case of domestic and foreign investment funds. The FTA has also issued information sheets not listed here to explain and clarify individual provisions.
As regards the taxation of investors in Switzerland, the respective cantonal tax laws must also be observed (these are not dealt with here).
1. Investment fund - portfolio
Stamp duty on transactions within the portfolio:
- Federal Law on Stamp Duty (StG) - German Version
- StG Ordinance (StV) - German version
- Circular No 12 on stamp duty (10.03.2011) - German version
Stamp duty on transactions within the portfolio:
- Federal Law on Withholding Tax (VStG) - German version
- VStG Ordinance (VStV) - German version
- FTA Circular n° 24 (anticipatory tax / stamp duty) (20.11.2017) - German version
- FTA Circular n° 25 (direct tax) (05.03.2009) - German version
2. Investment fund - application of income
The deduction of withholding tax on distributed and reinvested income and capital gains:
- Federal Law on Withholding Tax (VStG) - German version
- VStG Ordinance (VStV) - German version
- FTA Circular n° 24 (anticipatory tax / stamp duty) (01.01.2009) - German version
- FTA Circular n° 25 (direct tax) (23.02.2018) - German version
3. Investor
Purchase and redemption (sale) of units:
- Federal Law on Stamp Duty (StG) - German version
- StG Ordinance (StV) - German version
- Circular No 12 on stamp duty (10.03.2011) - German version
Income and capital gains on fund investments - Determined solely by the applicable provisions in the investor's tax domicile:
- FTA Circular n° 25 (direct tax) (23.02.2018) - German version
4. Fund provider
Value added tax on turnover generated by fund management companies and their agents, as well as remunerations to distributors: