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- Transitional provisions to the revision of the Stock Corporation Act of June 19, 2020
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- Art. 5 lit. c FADP
- Art. 5 lit. d FADP
- Art. 5 lit. f und g FADP
- Art. 6 para. 3-5 FADP
- Art. 6 Abs. 6 and 7 FADP
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- Art. 16 CCC (Convention on Cybercrime)
- Art. 18 CCC (Convention on Cybercrime)
- Art. 25 CCC (Convention on Cybercrime)
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- Art. 28 CCC (Convention on Cybercrime)
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- Art. 32 CCC (Convention on Cybercrime)
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- Art. 34 CCC (Convention on Cybercrime)
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- Art. 2a para. 1-2 and 4-5 AMLA
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FEDERAL CONSTITUTION
FEDERAL ACT ON DIRECT FEDERAL TAX
MEDICAL DEVICES ORDINANCE
CODE OF OBLIGATIONS
FEDERAL LAW ON PRIVATE INTERNATIONAL LAW
LUGANO CONVENTION
CODE OF CRIMINAL PROCEDURE
CIVIL PROCEDURE CODE
FEDERAL ACT ON POLITICAL RIGHTS
CIVIL CODE
FEDERAL ACT ON CARTELS AND OTHER RESTRAINTS OF COMPETITION
FEDERAL ACT ON INTERNATIONAL MUTUAL ASSISTANCE IN CRIMINAL MATTERS
DEBT ENFORCEMENT AND BANKRUPTCY ACT
FEDERAL ACT ON DATA PROTECTION
CRIMINAL CODE
CYBERCRIME CONVENTION
COMMERCIAL REGISTER ORDINANCE
FEDERAL ACT ON COMBATING MONEY LAUNDERING AND TERRORIST FINANCING
FREEDOM OF INFORMATION ACT
FEDERAL ACT ON THE INTERNATIONAL TRANSFER OF CULTURAL PROPERTY
FEDERAL ACT ON MEDICINAL PRODUCTS AND MEDICAL DEVICES
TAX HARMONISATION ACT
- I. Overview
- II. Regarding Art. 14(1) StHG
- III. On Art. 14(2) StHG
- IV. Re Art. 14 para. 3 StHG
- Bibliography
- Materials
I. Overview
1 Article 14 of the StHG governs the valuation of taxable assets and thus sets out in detail the provisions described in Article 13 of the StHG regarding the determination of the tax base for wealth tax purposes. Art. 14 StHG is thus to be understood as the link between the classification of an asset under wealth tax law and its quantification for wealth tax purposes.
II. Regarding Art. 14(1) StHG
A. Principle of valuation at market value
1. In general
2 According to Art. 14 para. 1 StHG, assets are generally to be valued at market value, although the income value may be taken into account appropriately. According to Federal Supreme Court case law, the market value corresponds to the price that would likely be realised in the ordinary course of business if the asset were sold on the valuation date. Only objective market conditions are decisive in this regard. Subjective factors, as well as prices agreed between friends or acquaintances, are disregarded. The market value is thus based on a twofold assumption: firstly, that a sale is in principle possible and that it takes place on standard market terms. Market value is not a precisely calculable figure, but is regularly determined by way of estimation or comparison. Secondly, the prices actually achieved on the market are subject to considerable fluctuations in some cases and may also contain speculative or subjective elements in individual cases.
3 The income value is furthermore derived from the capitalisation of the income generated by the asset, using a market-standard capitalisation rate.
2. Scope of the harmonisation provisions
4 Art. 14 StHG contains only basic guidelines for the valuation of the net assets determined in accordance with Art. 13 StHG. In particular, the StHG does not specify the specific methods to be used to determine the market value. The cantons therefore have considerable discretion both in the choice of valuation method and in deciding whether and to what extent the income value – as a discretionary provision – is included in the valuation. However, according to the established case law of the Federal Supreme Court, valuation methods that systematically lead to overvaluation or undervaluation are impermissible. According to the Federal Supreme Court’s reasoning, this is the case, for example, when a flat-rate discount is applied to the market value to determine the wealth tax value, or when only a specified percentage of the market value is taxed.
5 Under the harmonisation principle of market value assessment, the cantons are no longer free to assess individual asset categories using arbitrary valuation methods – such as book values, market prices or other values. Deviations from this principle are only permissible in the cases provided for under harmonisation law.
6 The limited regulatory scope of harmonised tax law thus leaves the cantons considerable discretion and, at the same time, relativises the scope of Federal Supreme Court case law. It is true that both the interpretation of the StHG and the compatibility of cantonal law with it are subject to free review by the Federal Supreme Court. However, insofar as the StHG deliberately grants the cantons a margin of discretion, judicial review is limited to compliance with constitutional limits, namely the prohibition of arbitrariness.
7 There are certain exceptions to the principle of market value assessment that are explicitly provided for under harmonisation law, and these are exhaustively regulated. One such exception, pursuant to Art. 14 para. 2 StHG, concerns land used for agricultural and forestry purposes, which must be valued on the basis of the income value. A further exception applies, pursuant to Art. 14 para. 3 StHG, to movable assets, including intangible assets, insofar as they form part of the taxpayer’s business assets. This must be recorded at the value relevant for income tax purposes. By contrast, immovable, non-agricultural assets – regardless of whether they are classified as private or business assets – must in principle be valued at market value within the meaning of para. 14 of StHG, although the income value may be taken into account appropriately.
8 For the sake of completeness, it should be noted that Art. 14a StHG, as a lex specialis provision for employee shareholdings, also provides for special valuation rules.
B. Valuation of assets pursuant to para. 14(1) StHG
9 If the market value cannot be determined on the basis of reliable comparative prices – e.g. using stock market prices – it must be estimated in accordance with generally accepted valuation principles. In properly conducted market value estimates, the income value is regularly taken into account in an appropriate manner. By contrast, the exclusive valuation of movable or immovable assets at the lower capitalised value is, in principle, impermissible and is provided for under harmonisation law only in the case of land used for agricultural and forestry purposes.
10 The following section addresses the valuation and, in particular, the methods developed by case law and administrative practice for determining the market value of those assets for which there are no special provisions under harmonisation law and which therefore fall under Art. 14 para. 1 StHG. This concerns movable private assets as well as immovable assets that are not used for agricultural or forestry purposes.
11 The focus of this commentary is to demonstrate the extent to which cantonal discretion is restricted by the case law of the Federal Supreme Court.
C. Valuation of movable private assets
1. Receivables and liabilities
a. Receivables
12 Case law on the valuation of receivables for wealth tax purposes is relatively consistent and can be summarised in a few key principles. The starting point is the nominal value principle. According to this principle, receivables are in principle taxable as assets at their full nominal value. This approach is recognised by the Federal Supreme Court as well as by the cantonal courts as an appropriate application of the concept of market value, because the nominal value generally corresponds to the value likely to be realised.
13 At the same time, case law emphasises that the nominal value is not a fixed figure and that a deviation from the nominal value is entirely possible. In this context, the probability of loss is of particular significance. The market value of a receivable is determined by its expected recoverability, which in turn is significantly influenced by the debtor’s income and financial circumstances. In a judgment of the Administrative Court of the Canton of Zurich, which was upheld by the Federal Supreme Court, the cantonal court stated that the debtor’s solvency, the existence of disputes, subordination of claims, conditions precedent or other objective risks that reduce the actual value of the claim must also be taken into account. In such cases, the increased risk of loss must be reflected by applying a discount. Complete exclusion for wealth tax purposes, however, is only considered in exceptional cases.
14 Furthermore, case law clarifies that the due date of a claim does not in itself influence its valuation. Non-interest-bearing receivables are also generally to be recorded at their nominal value. Only when additional factors come into play – such as a long term combined with a lack of terminability or structural risks – does a discount appear objectively justified.
15 A recurring theme in cantonal case law concerns the burden of proof. If the taxpayer wishes to deviate from valuation at nominal value, they must substantiate and provide evidence of the circumstances giving rise to a reduction in value. Mere general references to uncertainties or the absence of interest are not sufficient. Rather, the courts require comprehensible evidence, for example regarding the debtor’s financial situation or the lack of enforceability of the claim. In the absence of such evidence, the valuation at nominal value stands.
16 In summary, it can be stated that the courts approach the valuation of claims for wealth tax purposes with a pragmatic balance. The nominal value is the standard rule, whilst case-specific adjustments apply where objectively substantiated risks reduce the actual value.
b. Debts
17 Liabilities are generally to be recorded in accordance with the same valuation principles as the corresponding receivables. For the determination of market value, reference must therefore generally be made to the par or nominal value. Deviations are to be made – by analogy with the valuation of receivables – where liabilities are uncertain, cannot be precisely determined in terms of amount, are disputed, or are subject to suspensive or resolutive conditions.
2. Listed shareholdings or assets
18 The valuation of shares is largely determined by whether a stock market price or a relevant change of ownership reflecting the fair market value is available. If this is not the case, the wealth tax value must be determined using valuation methods.
19 Determining the market value of listed shares is relatively straightforward, as listed securities generally have a transparent market price. The guiding principle is that, for regularly traded securities, the closing price on the last trading day of the tax period reliably reflects the market value. This practice is endorsed by the Federal Supreme Court and forms the basis of cantonal valuation practice, as specified in particular in Circular No. 28 of the Swiss Tax Conference (KS 28 SSK).
20 The valuation of listed shares presents little potential for conflict under harmonisation law for the purposes of wealth tax.
3. Unlisted shares
a. Preliminary remarks
21 With regard to the valuation of unlisted shareholdings, KS 28 SSK plays a central role in practice. Although this is merely an administrative regulation, the guidance—which is geared towards cross-cantonal harmonisation—regularly reflects the administrative practice actually followed. At the same time, as ‘soft law’, it gives concrete form to Art. 14 para. 1 StHG and fills the scope that this provision deliberately leaves to the cantons. In the area of wealth tax, KS 28 SSK aims to ensure the most uniform possible valuation and assessment of domestic and foreign securities not listed on a stock exchange throughout Switzerland, thereby making a significant contribution to intercantonal tax harmonisation.
22 The practical relevance of KS 28 SSK for cantonal administrative practices is further demonstrated by the fact that – as far as can be ascertained – all cantons refer to it when there is no stock market price or relevant change of ownership for a shareholding and the market value must be determined using valuation methods. Depending on the canton, this is done either through explicit references in the implementing or enforcement ordinances to the cantonal tax laws or through corresponding references and adoptions in cantonal tax manuals or guidelines.
23 The Federal Supreme Court has already addressed specific issues within the scope of application of KS 28 SSK in a large number of decisions and has developed a nuanced body of case law in this regard. The following remarks serve in particular to demonstrate whether the principles developed by the SSK for determining the market value of unlisted shares are compatible with the requirements of harmonisation law. We shall not set out the principles for determining the market value for wealth tax purposes here, but refer to the relevant guidelines.
b. On the binding nature of KS 28 SSK
24 According to established case law of the Federal Supreme Court, KS 28 SSK is regarded as an appropriate and reliable method for determining the market value of unlisted securities, as it reflects the factors typically decisive for the pricing of such holdings. Accordingly – at least in the area of wealth tax – it is generally assumed that the guidelines must be applied when valuing unlisted securities. However, according to Federal Supreme Court case law, a deviation from this administrative regulation is appropriate if, in the specific case, a more substantiated and convincing determination of the market value is possible. Valuations of unlisted securities carried out on the basis of KS 28 SSK are, in principle, recognised and protected in Federal Supreme Court case law – with the exceptions set out below.
25 The Federal Supreme Court has deviated from the valuation principles of KS 28 SSK for the purposes of wealth tax in the following cases, amongst others:
The holdings held by a holding company were valued by the lower courts – in deviation from the requirements of KS 28 SSK – not individually using the average value or practitioner’s method, but collectively on the basis of the audited consolidated financial statements. According to the Federal Supreme Court, this approach is appropriate insofar as consolidation avoids unjustified multiple recognition of equity and fictitious profits from intra-group transactions, thereby preventing inflated net asset and income values.
According to the case law of the Federal Supreme Court, schematic valuation or estimation rules – such as those set out in KS 28 SSK – are not decisive, in particular, where the market value can be derived with sufficient certainty from actual transactions concluded at market-based prices. According to one interpretation of Federal Supreme Court case law, there is therefore no cantonal discretion regarding the determination of the wealth tax value if, for unlisted securities, there has been a relevant change of ownership that reflects the market value between independent third parties – as the concept of market value is interpreted by the Federal Supreme Court – or, more precisely: provided that the sale price reflects a representative and plausible market value.
c. On the consideration and weighting of the income value
26 Where the market value of unlisted shares is to be estimated using schematic methods, both Federal Supreme Court case law and cantonal administrative practice – as outlined above – are generally guided by KS 28 SSK. According to this, the income value must be included in the valuation, with varying weightings depending on the type of company.
27 In this context, the Federal Supreme Court held that a valuation approach based exclusively on net asset value raises serious doubts as to whether it still takes sufficient account of the principle of market value assessment enshrined in Art. 14 para. 1 StHG, without this question having been conclusively resolved.
28 However, the Federal Supreme Court appears – at least according to the interpretation put forward here – to be referring primarily to institutionalised valuation methods which schematically provide that shares are to be valued exclusively at net asset value. Conversely, it follows that, in the context of a case-by-case valuation, it may well be permissible to determine the wealth tax value exclusively on the basis of net asset value, provided that this method takes account of the actual economic circumstances and is not the result of a rigid, generalised valuation rule. Such an approach appears justifiable from the perspective of harmonisation law as well, in light of the cited Federal Supreme Court case law. According to Oesterhelt/Schreiber, a deviating valuation based on the specific circumstances is appropriate and permissible if, for example, a buy-back obligation enshrined in the articles of association or a shareholders’ agreement influences the effectively realisable market value. A corresponding case-by-case approach may well be compatible with Art. 14 para. 1 StHG and the case law of the Federal Supreme Court.
29 Furthermore, according to the case law of the highest court, the net asset value approach is not arbitrary and is therefore compatible with harmonisation law if a company has effectively ceased its operational activities and limits itself to holding or managing assets. Conversely, a sharp decline in turnover or staff reductions do not necessarily imply that a company is in liquidation. In such cases, taking the income value into account may, according to the Federal Supreme Court’s reasoning, still be appropriate and non-arbitrary.
d. Specifically regarding property companies
30 In the case of property companies, KS 28 SSK generally provides for the valuation of the holding at net asset value – as enterprise value. This must be distinguished from the valuation of undeveloped and developed land held by the property company. These are generally to be valued at market value. If this is not known, the valuation is based on the official valuation or the capitalised income value, but at least at book value.
31 In this context, the Federal Supreme Court held that the market value of the land may be determined by reference to market-based estimates – for example, using the comparative or statistical method. According to this case law of the Federal Supreme Court, the amount determined using the comparative or statistical method ultimately also represents an estimated market value. Neither KS 28 SSK nor the accompanying commentary suggests to the Federal Supreme Court that such a determination of market value should be ruled out. Where properties have been acquired at prices below the official valuation figures, the latter may nevertheless be used as a basis, provided that this takes appropriate account of the capitalised income values, as explicitly provided for under harmonisation law.
32 When valuing shareholdings in property companies, the question arises as to whether and to what extent deferred taxes – primarily deferred property gains tax – may be taken into account when determining the net asset value. KS 28 SSK provides that deferred taxes may generally be taken into account by applying a 15 per cent deduction to the untaxed hidden reserves included in the valuation. This covers taxes that would be due upon the realisation of the hidden reserves included in the net asset value calculation but which have not yet been taxed as income. The deduction for deferred taxes on immovable property is only possible if the land is valued at market value or capitalised value, or if the official valuation corresponds to the market value. The Federal Supreme Court has at least implicitly confirmed the inclusion of deferred taxes when determining the wealth tax value for holdings in property companies in accordance with the approach set out in KS 28 SSK. However, the Federal Supreme Court did not comment on whether, in addition to the solution provided for in KS 28 SSK, other methods for taking deferred taxes into account are permissible. It must therefore be concluded that the consideration of deferred taxes is, in principle, compatible with harmonisation law and that the rule laid down in KS 28 SSK constitutes a permissible specification of the requirements under harmonisation law. Against this background, the cantons retain discretion in the design of the deferred tax regime, in particular when determining the applicable tax rate. In substance, the deduction of deferred taxes means that the value for wealth tax purposes of a holding in a property company is generally below the net asset value and thus comes closer to the principle of valuation at market value according to para. 1 of Art. 14 of the Swiss Federal Fiscal Code.
e. Specifically regarding person-related companies
33 As the income value of person-related companies may, under certain circumstances, be difficult to realise, the question arises in the valuation of such shareholdings as to the weighting – whether single or double inclusion – of the income value. Under current administrative practice, upon application, the income value and net asset value may each be weighted once if the income is (almost) exclusively based on the performance of a person holding a majority stake (a stake of at least 50 per cent is taken as the benchmark, with the shares of jointly taxed spouses being aggregated) and – apart from a few support staff – no significant number of staff are employed. If the income is (almost) exclusively derived from the work of a majority shareholder (a holding of at least 50 per cent is taken as the benchmark, with the shares of jointly taxed spouses being aggregated) and, apart from a few assistants, there is no significant staff, the income value and net asset value may each be weighted simply upon application.
34 In a ruling on this matter, the Federal Supreme Court held that it is neither contrary to Art. 14 para. 1 StHG nor arbitrary to take the income value into account in the same way for single-member public limited companies as for multi-member public limited companies when carrying out a valuation. However, if the income value can only be realised to a limited extent, for example because it depends significantly on the personal work performance of the shareholder, it may be appropriate, according to the highest court’s case law, to simply weight the income value and net asset value equally. This also corresponds to the guidelines in the commentary on KS 28 SSK for companies with income that is difficult to sell and is person-dependent. However, in its case law regarding person-dependent companies, the Federal Supreme Court has held that it is not unrealistic for a reputation to be built up, despite the person-dependent nature of the business, which is detached from the individual employee and, as such, establishes an independent market value.
35 According to the relevant case law and administrative practice, however, a complete disregard of the earnings value in the case of operationally active companies does not generally appear appropriate. In this regard, the Federal Supreme Court took the view that a valuation of person-related service companies based exclusively on net asset value would systematically undervalue them and thus contradict the market value assessment required by Art. 14 para. 1 StHG.
36 Furthermore, the Federal Supreme Court clarified that, when valuing unlisted shareholdings, it is irrelevant if the shareholder forgoes a market-standard salary and thereby increases the value of their shareholding.
f. On the flat-rate deduction
37 The Federal Supreme Court has repeatedly ruled on minority shareholdings. According to established case law of the Federal Supreme Court, the granting of a flat-rate minority discount is excluded if the taxpayer in question, despite holding a formal minority stake, effectively exercises a controlling or cumulative influence, for example in the case of spouses with a combined majority stake. Minority shareholdings held by spouses must therefore, in principle, be aggregated, unless it can be credibly demonstrated that they are managed and disposed of independently. In our view, the same conclusion must be reached where a company is subject to control by means of a shareholders’ agreement. Conversely, a minority discount may also be justified in the case of a 50% holding if the co-shareholder does not have a controlling influence due to the company’s legal structure.
g. Factors extending beyond the valuation date
38 Furthermore, the Federal Supreme Court held that it is not arbitrary to take into account, when determining market value, indicators that materialise shortly after the valuation date and allow reliable conclusions to be drawn regarding the determination of market value. Thus, the Federal Supreme Court did not consider it arbitrary to use the purchase price agreed in a purchase agreement as a reliable indicator of the market value, even though the purchase agreement was not concluded until the middle of the following year and was backdated to 1 January of that year. According to the case law of the Federal Supreme Court, it is therefore permissible to also use recent events from the subsequent tax period to determine the market value.
h. Digression: Divergence between income tax and wealth tax values
39 The Federal Supreme Court also held that the valuation rules for income tax and wealth tax do not have to be identical. A divergence between the book value or income tax value on the one hand and the wealth tax value on the other was deliberately provided for by the tax harmonisation legislature, or at least accepted. There is evidently no coordination rule from which a priority of one type of tax over the other could be derived. Had the tax harmonisation legislature intended such a hierarchy, it would have had to stipulate it expressly, as has been done, for example, for intangible assets and movable assets of the business estate. For these, Art. 14 para. 3 StHG expressly provides that they are to be valued at the value relevant for income tax.
4. Valuation of immovable property not used for agricultural purposes
a. Preliminary remarks
40 Land not used for agricultural or forestry purposes is, in principle, to be valued at market value, although the income value may in turn be taken into account appropriately. This valuation principle applies regardless of whether the land forms part of the taxpayer’s private or business assets. The deviation from the market value principle provided for in para. 14(3) StHG applies exclusively to movable business assets, for which the income tax value is decisive.
b. Definition of immovable non-agricultural assets
41 The StHG contains no provisions regarding the division of net assets into immovable and movable components. Whether and how property taxation is linked to the nature of the land therefore depends on cantonal law. Accordingly, photovoltaic systems, which, as shown, are subject to property taxation, may, depending on cantonal regulations, either be included in the official land valuation or be taxed as independent movable assets.
c. Harmonisation requirements
42 Even for immovable assets not used for agricultural purposes, the StHG neither specifies the methods by which the market value is to be determined, nor does it clarify the conditions under which the income value must be appropriately taken into account. This again leaves the cantons with considerable scope for regulation and application, within which they may – to a certain extent – also take property policy considerations into account for residential buildings.
d. Specific challenges
43 The Federal Supreme Court acknowledges that the valuation of land – irrespective of the specific method applied – is subject to a certain degree of uncertainty. This unavoidable imprecision is reflected in a range of results that corresponds to the reality of property valuation. Against this background, it is in principle permissible to determine the wealth tax value for non-agricultural land on the basis of schematic and conservative estimates, provided that these take account of the necessary categorisation and the inevitable uncertainty in valuation.
44 Given the considerable discretion enjoyed by the cantons, the Federal Supreme Court considers it permissible for the property tax values to ultimately lie more or less significantly below the actual market value. If, on the other hand, a general valuation rule were designed to achieve an average wealth tax value of 100 per cent of the market value, there would inevitably be a risk that this would exceed the actual market value in a large number of cases. In such circumstances, according to the case law of the highest court, an asset value would be taxed that does not actually exist, which contravenes the harmonisation requirement.
e. Methods for determining the property tax value
45 Various valuation and estimation methods are available for determining the market value of real estate; their suitability depends on the nature of the property being valued and the specific purpose of the valuation. A collection and explanation of relevant methods can be found in the valuation handbook ‘Das Schweizerische Schätzungshandbuch, Bewertung von Immobilien’ published by the Swiss Association of Cantonal Property Valuation Experts (SVKG) and the Swiss Valuation Chamber/Swiss Association of the Real Estate Industry (SEK/SVIT). Several cantonal administrative practices declare this to be applicable to their valuations of immovable property. Cantonal case law has also already recognised the valuation handbook as generally accepted practice. Federal Supreme Court case law contains no explicit reference to this – as far as can be ascertained and unlike in relation to KS 28 SSK – indicating that the Federal Supreme Court would rely on the aforementioned Valuation Manual or the guidelines described therein when determining the market value of land for wealth tax purposes.
46 According to Roesch/Pandurski, the cantonal valuation approaches for determining the wealth tax value of land can essentially be divided into two groups. A first group uses mixed-value models that combine cost and income approaches. Although this method is recognised by experts, it is considered outdated in property valuation theory and is increasingly being abandoned due to its complexity.
47 A second group relies primarily on the cost or real value for the calculation of the wealth tax value. However, this approach is criticised by Roesch/Pandurski from a valuation and harmonisation law perspective, as the cost value on its own does not reflect market value and, in particular, systematically favours investment properties. Particularly critical in this regard are models based on insurance or fire insurance values or those using schematic capitalisation rates, as they lack a market reference. In any case, a market-based approach to the market value is necessary for a proper valuation of assets.
48 According to Federal Supreme Court case law, the price comparison method is regarded as the most reliable method for determining the property tax value of land, provided it is based on a statistically sufficient number of suitable comparative prices. The price comparison method is particularly suitable for the valuation of land and constitutes the primary method in this area. By contrast, the location class method primarily serves as an auxiliary method.
f. Valuation by property type
49 Cantonal administrative practices regularly differentiate the specific determination of market value by property type. In the case of developed land – particularly owner-occupied and let properties – the market value may, in practice, also be derived using a capitalisation approach, provided the capitalisation is market-oriented, which has been deemed a permissible method by the Federal Supreme Court. In contrast, undeveloped plots of land not used for agricultural purposes typically generate no income or only a minor income, which is why the market value is typically determined using comparative prices or market-based models. Irrespective of this, it is crucial that the valuation method as a whole remains close to the market value and does not veer into a schematic undervaluation or overvaluation detached from the market. Furthermore, it appears permissible under both constitutional and harmonisation law to differentiate between second homes and owner-occupied primary residences when determining the wealth tax value. As far as can be ascertained, there is no Supreme Court ruling on this specific issue.
g. Federal Supreme Court guidelines regarding the determination of the wealth tax value
50 The Federal Supreme Court has repeatedly ruled that cantonal regulations which systematically set the wealth tax value significantly below market value are contrary to federal law. Thus, valuation practices were rejected which set the wealth tax value ‘as a rule at 60 per cent of the market value’ or at ‘70 per cent of the estimated value’. The same applies to regulations that effectively resulted in average valuations of around 61 or 59 per cent of market value. According to the Federal Supreme Court, such approaches fail to meet the definition of market value under Art. 14 StHG, as they amount to structural undervaluation and thus contravene the requirements of harmonisation law.
51 By contrast, the Federal Supreme Court has on several occasions deemed cantonal valuation models to be permissible under harmonisation law where the estimates at the upper end of the valuation range do not exceed the actual market value, even if this results in property tax values generally falling between 70 and 100 per cent of the market value. According to the highest court’s case law, it is also compatible with Art. 14 para. 1 StHG to aim for a target value of 90 per cent of the market value when using formulaic valuation methods, in order to avoid inflated market values in individual cases.
52 As explained, both a general undervaluation of 70 per cent and an overvaluation of 100 per cent of the actual market value are contrary to harmonisation. Within this framework defined by the Federal Supreme Court, however, the cantons are free to provide for adjustments where the valuation methods applied result in values outside this range. The decisive factor is that the property tax values determined by way of correction comply with the framework prescribed by federal law.
53 Conversely, schematic solutions providing for a flat-rate discount motivated by property policy are also inadmissible, as such regulations would in turn lead to valuations that are systematically significantly below the real value. A flat-rate and linear discount must, however, be distinguished from the cautious valuation resulting from the inherent uncertainty in property valuation.
54 In accordance with the above, the property tax value for immovable property may be determined by means of schematic and conservative estimates that take account of the inevitable schematisation and the inherent uncertainty of any valuation. If such methods result in tax values that, on average, fall below the actual realisable market value, this is permissible within certain limits. The prerequisite is that the deviation is objectively justified by the inaccuracy of the valuation and does not result from systematic undervaluation. Overall, Federal Supreme Court case law requires a cautious and moderate approach to the valuation of immovable property, which serves in particular to avoid overvaluation and the taxation of assets that cannot be realised.
55 The cantonal discretion regarding the consideration of the income value of immovable property is limited by the fact that – with the exception of land used for agricultural and forestry purposes in accordance with Art. 14 para. 2 StHG – a valuation may not be based exclusively on the income criterion without taking the market value into account. The income value may only be taken into account in an appropriate manner and cannot, on its own, justify any arbitrary deviation from the market value.
56 In light of the above, cantonal valuation systems which determine the wealth tax value on a flat-rate basis and exclusively according to the income value, whilst disregarding the market value, would in principle be classified as impermissible.
57 The case law of the Federal Supreme Court on wealth tax valuation issues is also of particular interest with regard to the scope of cantonal discretion. Whilst the Federal Supreme Court, when valuing movable assets – notably unlisted shareholdings – adheres almost stoically to the guidelines of KS 28 SSK, it grants the cantons significantly broader discretion regarding permissible valuation methods when determining the wealth tax value of immovable property.
h. Encumbrances and appurtenances
58 Encumbrances on a property must be taken into account as value-reducing factors in its valuation to the extent that they actually impair the objective market value. The economic value of easements and encumbrances must be added to the value of the property holding the right and deducted from the value of the encumbered property. Mortgages, on the other hand, are not taken into account when valuing land, as they are to be classified as taxable movable assets for the creditor and as deductible debts for the debtor.
59 Personal servitudes and registered personal rights, by contrast, do not generally reduce the value of the encumbered property. This is subject to the special provision on usufruct under Art. 13 para. 2 StHG.
60 Components and appurtenances of a property, as well as the associated rights of use, must be taken into account as value-enhancing factors in the valuation, provided they do not qualify as independent taxable objects. Whilst components are inseparably linked to the property under civil law and cannot be subject to separate rights, appurtenances may be legally independent. This civil law distinction must also be consistently taken into account in the allocation and valuation for wealth tax purposes.
61 The valuation of immovable property is also significant with regard to the allocation of liabilities according to the location of the assets, as this is based on the respective values determined for these assets. If individual assets are undervalued, this results in fewer liabilities and interest on liabilities being allocated to the relevant canton than would be the case under a uniform valuation standard.
62 To ensure uniform valuation in the distribution of debts and debt interest in the intercantonal context, so-called distribution factors were introduced by Circular No. 22 of the Swiss Tax Conference (KS 22 SSK). These factors are periodically adjusted to reflect changes in property values and serve to convert cantonal differences in wealth tax values into comparable apportionment values. The Federal Supreme Court has repeatedly recognised the apportionment factors as suitable and permissible correction instruments for intercantonal tax allocation.
63 The apportionment values – as the Federal Supreme Court expressly states – are relevant only for the allocation of liabilities, but not for the valuation of assets. In this respect, the market values determined in accordance with cantonal law remain the sole determining factor. It would be incompatible with both the prohibition on disadvantage and the harmonisation requirement to value assets at market value to increase the wealth tax value of a property owned by a taxpayer liable for tax in several cantons to a distribution value that exceeds the taxable market value of the property on which a taxpayer liable for tax only in the canton of location would be required to pay tax.
i. Valuation cycle
64 In terms of timing, harmonised tax law stipulates that wealth tax must be levied annually and is based on the value of assets at the end of the tax period or the tax liability. The Federal Supreme Court has concluded from this that tax harmonisation law prohibits the cantons from determining or updating asset values only at longer intervals. Valuation models that fail to adjust asset values over several years and thereby increasingly diverge from actual market conditions are incompatible with the Federal Act on the Harmonisation of Taxation (StHG). Cantonal regulations providing for such static values thus violate harmonisation law, as they contradict the legally required period-based and reference-date-related taxation of assets.
5. Cryptocurrencies and digital assets
65 For wealth tax purposes, crypto assets are generally to be treated in the same way as foreign currencies and must be declared in the securities and assets register. The relevant market value is the exchange rate as at 31 December, whereby the FTA – in line with securities listed on Swiss stock exchanges – publishes an official price list for the most common crypto assets. Digital assets not listed therein are to be valued on the basis of the prices on trading platforms.
66 With NFTs, determining value is often difficult because individual high sale prices do not necessarily reflect the market value due to the lack of a liquid secondary market. In principle, the same valuation principles apply to digital artworks as to physical art, which is often difficult to value due to its uniqueness.
67 Difficulties may arise with tokens lacking a liquid market – namely utility tokens and certain asset tokens. Their fair market value must be estimated on a case-by-case basis, although significant uncertainties regarding the relevant methodology exist due to the lack of Federal Supreme Court case law. It is also unclear under harmonisation law whether DeFi positions (e.g. staking, liquidity pools) are to be classified as separate assets – which would in turn need to be valued – or as part of the underlying tokens.
III. On Art. 14(2) StHG
A. Harmonisation law requirement
68 As the sole explicit deviation from the principle of valuing immovable property at market value, Art. 14(2) StHG stipulates that land used for agricultural and forestry purposes must be valued at its income value.
B. On the classification as land used for forestry and agriculture
69 The StHG does not contain a separate definition of land used for forestry and agriculture. In its case law on Art. 8(1) and Art. 12(1) StHG, the Federal Supreme Court has clarified that the harmonised concept of land used for forestry and agriculture must not be interpreted in isolation under tax law, but systematically, taking into account the objectives of the Federal Act on the Structure of Land Ownership (BGBB), the Spatial Planning Act (RPG) and the Agricultural Act (LwG). According to the Federal Supreme Court, tax privileges for agricultural and forestry land are, in principle, justified only if the conditions for the applicability of the Federal Act on the Coordination of Land Use Planning (BGBB) are met. This is notably the case for land outside the building zone that is permitted for agricultural use, or in the other scenarios provided for by law in accordance with para. 2 of Article 2 of the BGBB.
70 It should be noted, however, that for the application of Art. 14 para. 2 StHG, it is not the classification as agricultural or forestry land that is decisive, but the actual agricultural use. According to Würsch, agricultural use may, however, also exist in the case of land not subject to the BGBB, but always presupposes actual use. If such use is wholly or partially absent, the property tax value must be determined in accordance with the market value principle laid down in Art. 14 para. 1 StHG. By ‘agricultural use’, Würsch understands core agriculture as defined in Art. 3 para. 1 of the Agricultural Act (LwG). This includes the production of crop and livestock products, as well as their processing, storage and sale, and the management of near-natural areas. Other activities, such as fishing, horticulture or beekeeping, are not included.
71 The Federal Supreme Court has left open the question of whether the cantons have an independent discretion under harmonisation law when distinguishing between land used for agricultural or forestry purposes. It has, however, repeatedly confirmed that restricting income-based taxation to land falling within the scope of the Federal Act on the Structure and Development of the Swiss Economy (BGBB) is compatible with Article 14(2) of the Federal Act on the Harmonisation of Taxation (StHG), without thereby definitively ruling on the extent of the cantons’ discretion.
C. Valuation of land used for forestry and agriculture
72 The cantons nevertheless retain a degree of discretion in two respects. Firstly, they may take the market value into account in the valuation. Whilst Art. 14(1) StHG expressly limits the consideration of the income value in the market value assessment to an ‘appropriate’ extent, no such restriction is found in para. 2. Tax law literature assumes that, in this case, the cantons are required to take the market value into account only to the extent that the valuation based on the income value is not undermined. The deliberately open-ended wording of the StHG thus leaves the cantons considerable discretion, which is reflected in practice in significantly differing cantonal arrangements. On the other hand, Art. 14 para. 2 StHG expressly provides that in the event of a subsequent sale or change of use of the property – within a maximum of twenty years – a supplementary wealth tax (retroactive taxation) may be levied.
D. Specifically regarding valuation based on the income value
73 The income value for land used for agricultural and forestry purposes is determined in accordance with Art. 10 of the Federal Act on the Introduction of the Swiss Civil Code (BGBB). This refers to the capital which, in the course of the customary management of an agricultural business or plot of land, can be capitalised at the average interest rate for first mortgages using the achievable yield. In determining both the relevant income and the interest rate, reference must be made to average values over several years. The specific valuation is carried out in accordance with Art. 2 VBB. In this regard, the individual valuation method must generally be applied rather than the gross income method. Each component of an agricultural holding – namely land, buildings and woodland – must be valued separately and in accordance with the relevant guidelines.
E. Supplementary wealth tax
1. Harmonisation requirement
74Art. 14 para. 2 StHG grants the cantons, by means of an alternative discretionary provision, the option to levy a supplementary wealth tax upon the sale of land used for agricultural or forestry purposes which was taxed at its income value during its privileged use, or upon the cessation of agricultural or forestry use. The basis for assessment of the retrospective tax is the difference between the income value and the market value. The tax must be limited in time to the past 20 years.
75This supplementary wealth tax was already in use in several cantons prior to the entry into force of the StHG. It is based on the consideration that the market value accrues to the owner in economic terms already during agricultural or forestry use, but is only realised upon disposal or a change of use – for example, through development. The retrospective taxation is therefore intended to compensate for the under-taxation resulting from taxation based on the income value, which is in some cases not objectively justified.
2. Determination of market value
76 The StHG contains no provisions regarding the criteria by which the market value relevant for the supplementary wealth tax is to be determined. This leaves the cantons a certain degree of discretion in this matter as well. Accordingly, the Federal Supreme Court’s review of the cantonal regulations and their application is again limited to assessing arbitrariness.
IV. Re Art. 14 para. 3 StHG
A. Harmonisation requirement
77 Under Art. 14 para. 3 StHG, movable business assets – including intangible assets – are to be valued at their income tax value. The explicit mention of intangible assets is of a rather declaratory nature, as these are in any case to be classified as movable assets.
78 With the STAF tax reform, para. 14(3) StHG was amended to the effect that the cantons have since been able to provide for a tax reduction for assets comprising patents and comparable rights within the meaning of Art. 8a StHG. The Corporate Tax Reform Act II had already previously repealed the former special provision under which securities in business assets were to be valued at market value. Since then, securities in business assets have also been uniformly subject to valuation at the income tax value.
B. Scope of the harmonisation provision
79 This harmonisation provision mandatorily stipulates that movable business assets must be assessed for wealth tax purposes at their income tax value. According to the wording of Art. 14 para. 3 StHG, a deviating valuation—such as a market-oriented one—would, for example, be incompatible with harmonisation law. The cantons’ discretion is thus limited to the determination of value under income tax law itself, but not to the introduction of alternative valuation criteria for the purposes of wealth tax.
C. Valuation at income tax value
80 The income tax value corresponds to the value of movable business assets, including intangible assets, which is decisive for income taxation. For taxpayers who keep accounts, this is generally the tax-adjusted book value. For self-employed persons who do not keep accounts, the value determined on the basis of records and depreciation tables must be used, provided it complies with tax law.
81 Hidden reserves attached to these assets may not be taken into account by the cantons when valuing the business. Consequently, a form of the ‘relevance principle’ applies to the wealth taxation of the business assets of self-employed persons. The value for income tax purposes is decisive and is also adopted for wealth tax purposes, subject only to the tax adjustments expressly provided for by law.
82 In summary, it follows that Art. 14 para. 3 StHG brings about a selective but mandatory harmonisation. For movable business assets, wealth tax is systematically linked to the income tax value. Whilst the StHG leaves the cantons considerable leeway in other areas – in particular regarding the determination of market value under Art. 14 para. 1 StHG – this leeway is deliberately restricted within the scope of application of Art. 14 para. 3 StHG. Disputes thus shift less to the valuation as such, but primarily to the prior classification of an asset as business or private assets.
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Materials
Baselbieter Steuerbuch, Band 1 – Vermögen 46 Nr. 2 Bewertung von Wertpapieren ohne Kurswert vom 23.1.2026, https://kanton.baselland.ch/finanz-und-kirchendirektion/steuerverwaltung-steuerbuch/band-1/vermogen/downloads-1/band1_046_02.pdf/@@download/file/band1_046_02.pdf, besucht am 25.2.2026.
Luzerner Steuerbuch, Band 1 – Vermögenssteuer § 47 Nr. 2: Bewertung von Wertpapieren ohne Kurswert vom 1.1.2024, https://steuerbuch.lu.ch/band1/vermoegenssteuer/bewertung_von_wertpapieren_ohne_kurswert, besucht am 25.2.2026.
Luzerner Steuerbuch, Band 1 – Vermögenssteuer § 48 Nr. 1: Unbewegliches Vermögen vom 1.1.2024, https://steuerbuch.lu.ch/band1/vermoegenssteuer/unbewegliches_vermoegen, besucht am 29.1.2026.
Schweizerische Steuerkonferenz, Kommentar 2025 zum Kreisschreiben Nr. 28 zur Bewertung von Wertpapieren ohne Kurswert für die Vermögenssteuer vom 28.08.2008, https://www.ssk-csi.ch/fileadmin/dokumente/kreisschreiben/KS_28_-_Kommentar_D_-_2025.pdf, besucht am 25.2.2026.
Schweizerische Steuerkonferenz, Kreisschreiben Nr. 22 betreffend Regeln für die Bewertung der Grundstücke bei interkantonalen Steuerausscheidungen ab Steuerperiode 2002 (Repartitionsfaktoren) vom 22.3.2018 (geändert am 4.2.2026), https://www.ssk-csi.ch/fileadmin/dokumente/kreisschreiben/260204_Kreisschreiben_Nr._22_Repartitionsfaktoren_D_neu.pdf, besucht am 25.2.2026.
Schweizerische Steuerkonferenz, Kreisschreiben Nr. 28 zur Bewertung von Wertpapieren ohne Kurswert für die Vermögenssteuer vom 28.8.2008 in der aktualisierten Fassung vom 12.2022, https://www.ssk-csi.ch/fileadmin/dokumente/kreisschreiben/KS_28_d_2022.pdf, besucht am 25.2.2026.
Schweizerische Steuerkonferenz, SSK Steuerinformation zur Vermögenssteuer natürlicher Personen 2024, https://www.estv2.admin.ch/stp/ds/d-vermoegenssteuer-np-de.pdf, besucht am 29.1.2026.
St.Galler Steuerbuch, StB 56 Nr. 1 Wertpapiere ohne Kurswert vom 1.1.2025, https://www.sg.ch/content/dam/sgch/steuern-finanzen/steuern/steuerbuch/art-53-69-stg/056_1.pdf, besucht am 25.2.2026.
St.Galler Steuerbuch, StB 57 Nr. 1, Vermögenssteuerwert von Grundstücken vom 1.7.2021, https://www.sg.ch/content/dam/sgch/steuern-finanzen/steuern/steuerbuch/art-53-69-stg/057_1.pdf, besucht am 25.2.2026.
Wegleitung Immobilienbesteuerung des Kantons Zug vom 10.2013, https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://zg.ch/dam/jcr:39bca91d-36cc-4416-ab0d-6fe44e0be3b3/Immobilienbesteuerung.pdf&ved=2ahUKEwjjoYPy3b2TAxVd_7sIHbx6LfQQFnoECBYQAQ&usg=AOvVaw1sQ5i1AXox8nxi4ft5rs_K, besucht am 29.1.2026.