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Strengths of the Canton of Berne > Taxes > Taxation of a body corporate
 
Taxation of a body corporate
A favorable tax climate is one of the most important conditions for sound economic development. For this reason, the Canton of Berne has made every possible endeavor to create a fiscally attractive environment. A comparison with the situation nationally and internationally shows that the tax climate for companies in the Canton of Berne is very favorable. In addition, especially low rates of tax apply to holding and domicile companies.

Income from single proprietorships or partnerships is taxed together with an individual’s other income. The tax levied on the business assets of a single proprietorship or partnership is very moderate. Depending on the type of entity it is taxed either in whole or in part together with an individual’s other assets.

A progressive, triple-tier tax rate is applied to the profit of a body corporate, irrespective of profitability.

The capital tax of a body corporate is very low (approximately 0.144%) and is levied irrespective of a company’s profits.

As a rough estimate, the company tax for a small- or medium-sized company in the Canton of Berne is only:
Approx. 20% of pre-tax profits
Approx. 25% of profits after tax

Stock Corporations
Taxation of stock corporations (without any preferential status) at the cantonal and municipal level:
A profit tax rate of 7% to 15% on pretax profit, or a maximum of 19% when tax is applied to after-tax profits.
Added to this a tax of ca. 0.144% on equity (share capital and taxed disclosed and undisclosed reserves).

Even more advantageous tax conditions apply in the Canton of Berne to preferential-status stock corporations such as holding companies and (mixed) domiciliary companies (management companies).

Holding companies
Corporations whose earnings come from holdings, whether in whole or in part, benefit from very low tax rates: Any company whose main purpose is acquiring financial holdings in other companies is granted the status of a holding company. Consequently, holding companies throughout Switzerland have to satisfy one of the following criteria:

  • two thirds of the company’s assets is comprised of holdings
    or
  • two thirds of the company’s gross earnings is attributable to income from holdings

Municipal and cantonal profit tax is dispensed with for holding companies; the capital tax rate is also substantially reduced and is levied on a sliding-scale basis:

In so doing, the Canton of Berne provides extremely attractive locational conditions for holding companies, in particular competence centers with an international orientation and corporate headquarters with high equity

Domiciliary and mixed domiciliary companies
Companies that have only their head office in the Canton of Berne, however have no business activities in Switzerland or business activities of an insignificant nature, benefit from the status of domiciliary company:
The capital tax levied on domiciliary companies (operating mainly or exclusively outside of Switzerland) corresponds to that of a holding company

Profits tax

  • Income from domestic and foreign holdings as well as capital gains and revaluation gains are tax-exempt.
  • Other income from Swiss sources is subject to ordinary profit tax.

Other income from foreign sources is subject to profit tax only to a moderate extent; the amount of tax payable is in keeping with the significance of the business activities of a company’s head office in relation to those of the company as a whole. Income of this type is completely tax-exempt if no or very little staff is employed. This income is also tax-exempt if it is taxed or is taxable outside of Switzerland. If a domiciliary company’s business activities in Switzerland are of a subordinate nature, then the tax levied on foreign-source income is in keeping with the extent of the company’s business activities in Switzerland.

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