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      The taxation of real estate transactions in Switzerland is complex and heavily influenced by cantonal variations. Whether it is a direct sale of real estate, an indirect sale via a real estate company, a restructuring, a land swap or an intra-family transfer – capital gains tax on real estate almost always plays a key role.

      This page provides a compact overview of the main types of transactions, highlights important tax considerations and offers practical guidance for forward-looking tax planning. The goal is to manage risks, make use of structuring opportunities and identify the right solution for each individual situation.

      The articles linked on this page are in German.

      Christoph Frey
      Christoph Frey

      Partner, Real Estate Tax

      KPMG Switzerland

      Property sales & tax: real estate capital gains tax in Switzerland

      Real estate capital gains tax (RECGT) is levied at cantonal level in Switzerland and applies to the sale of real property. 

      It affects both individuals and legal entities, is property-specific and triggered by the disposal of a property located in Switzerland. 

      Its relevance extends well beyond the sale of a single-family home and can create complex challenges in cases such as the sale of real estate companies, succession planning or corporate restructurings. 

      Sale of properties

      Direct sale; Asset deal

      In the private sphere, capital gains tax is levied on the difference between the sales proceeds and the investment cost. Investment costs include the original purchase price as well as value-enhancing investments. In so-called monistic cantons, the same principle applies to properties held as business assets. 

      The seller alone is tax liable. However, in practice many cantons secure their claim via a statutory lien on the property, which may indirectly affect the purchaser. In addition, most cantons apply a time-dependent tax rate (degression model) based on the holding period.

      Sale of real estate companies

      Indirect sale; Share deal

      When selling a real estate company, there is no direct property sale, as only the shares are transferred. Nevertheless, a transfer may still be treated as an economic change of ownership, triggering capital gains tax for the seller.

      The rules differ from canton to canton, and thorough analysis is essential. Any latent corporate income tax remains within the company and will affect pricing, with the exact treatment becoming a matter of negotiation.

      • Points to consider
        • Selling a real estate company is generally advantageous for the seller (tax-free private capital gain)

        • The purchaser inherits the company’s tax history and risks. Due diligence is critical to identify tax and legal risks

        • Executing a share deal is more complex than an asset deal

        • Both intercantonal and international aspects must be reviewed 

      Restructurings

      Restructurings such as mergers, spin-offs or transfers of assets can generally take place tax-neutrally if real estate and other assets are transferred at book value.

      In practice, business purpose requirements may apply – for example, real estate companies may need to demonstrate a minimum rental income of CHF 1.6–2 million. In addition, blocking periods can apply and require careful consideration.

      • Points to consider

        • Structuring with tax deferral

        • Obtaining rulings from tax authorities

      Property swaps

      In a swap, both parties are deemed sellers for tax purposes, meaning that each transaction is taxable, and two taxable events arise. 

      • Points to consider

        • Properties must be valued correctly at fair market value

        • The possibility of tax deferral should be examined (e.g. replacement purchase)

      Donation, inheritance and transfers

      Within the family – to the next generation  

      Where real estate is gifted, inherited or transferred within the family, no real estate capital gains tax is payable in general. However, depending on the canton, gift or inheritance taxes may apply.

      If the property is later sold by the recipient or the heir, the original acquisition cost and date apply.

      • Points to consider
        • Any consideration provided must be accounted for (e.g. mortgage assumption, usufruct, right of residence – so-called “mixed donation”)

        • Obtaining rulings from tax authorities

      Key considerations in real estate capital gains tax

      Pension institutions have a special tax deductibility for energy-saving measures.

      Learn more

      No RECGT for pension funds when transferring properties into an investment foundation.

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      When selling shares of a real estate company held privately, the RECGT paid by the company can be taken into account.

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      Investment costs play a major role in the calculation of the RECGT.

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      Confirmed: Loss offsetting of the RECGT across different cantons is permitted.

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      Profit allocation in the two-contract model will likely be subject to stricter scrutiny in the future.

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      Real estate capital gains tax: Cross-cantonal loss compensation for pension institutions.

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      Equal legal treatment for Zurich companies regarding the RECGT.

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      What matters in tax planning

      • Planning taxes early

        Proper preparation avoids unnecessary taxes.

      • Being aware of cantonal specifics

        Rules between cantons vary widely.

      • Obtaining tax rulings

        Particularly advisable in restructurings and indirect sales.

      • Securing documentation and evidence

        Records and receipts are key – especially for investments, long holding periods, and deferrals.

      • Seeking professional support

        Tax advisors, trustees and legal experts should be involved in complex transactions. 

         

      Real estate capital gains tax is at the heart of most real estate-related transactions in Switzerland. 

      Complex challenges often arise in indirect sales, restructurings, determination of investment costs, cross-cantonal loss offsetting, chain transactions, the two-contract model, or special cases such as asset swaps involving pension funds. 

      Cantonal and municipal differences are highly significant in practice.

        Your real estate – Structured the right way

        We support you across the full spectrum of transactions – from sales to family transfers. Contact our tax experts to discuss your individual needs.

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        Our team of experts

        Please don’t hesitate to contact us with your tax-related matters. Our real estate tax team is ready to advise you.

        Christoph Frey
        Christoph Frey

        Partner, Real Estate Tax

        KPMG Switzerland

        Janick Pochon
        Janick Pochon

        Partner, Tax

        KPMG Switzerland

        Markus Bürkler
        Markus Bürkler

        Director, Tax

        KPMG Switzerland

        Sibylle Fankhauser
        Sibylle Fankhauser

        Director, Tax & Legal

        KPMG Switzerland

        How KPMG supports you in optimizing your real estate strategy 

        Real Estate Tax

        We provide you with competent advice on all tax aspects of your Swiss and international real estate investments.

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