Current Tax Developments: Individual Taxation, Elimination of the Imputed Rental Value, and New Loss Carryforward Period

Current Tax Developments: Individual Taxation, Elimination of the Imputed Rental Value, and New Loss Carryforward Period
09/2026
Michael Kistler
Michael Schneider
Our tax experts have compiled a selection of tax topics that will be particularly relevant in the coming months: new legal requirements, upcoming votes, and tax changes will bring important developments for both businesses and individuals.

1. Individual Taxation Starting in 2032 – Further Vote in November

On August 19, 2026, the Federal Council decided to introduce individual taxation effective January 1, 2032. This will make full use of the transition period provided for by law. In particular, this will give the cantons more time to adapt their tax laws and the necessary technical processes. Among other things, this will require a review of the current tax rates and social deductions, some of which will need to be restructured.

Even before the introduction of individual taxation, another important vote will take place on November 29, 2026: The people and the cantons will decide on the popular initiative “Yes to Fair Federal Taxes for Married Couples, Too—Let’s Finally End Discrimination Against Marriage!” The initiative continues to provide for the joint taxation of married couples, combined with an alternative method of calculating taxes.

If the initiative were to be approved, it would not automatically repeal the federal law on individual taxation that has already been enacted. The cantons’ obligation to introduce individual taxation would only be lifted if Parliament were to amend the relevant law again and that amendment were to take effect by 2032. Depending on the outcome of the vote on Sunday, November 29, 2026, the already challenging implementation of the approved system change could become even more complex.

2. Update on the Elimination of the Imputed Rental Value

In connection with the votes on tax law, the reform of home ownership taxation is also worth mentioning. The Federal Council has decided to implement this reform—and thus the abolition of the imputed rental value—effective January 1, 2029. For private homeowners, this means that renovations and investments in their homes planned through the end of 2028 can be carried out under the current tax framework. Special attention should also be paid to the limited deductibility of private mortgage interest, which will take effect in 2029 (see our September 2025 newsletter: https://www.gfeller-partner.ch/news/news-zur-abstimmung-am-28-september-2025-systemwechsel-beim-eigenmietwert). Numerous implementation issues are currently still under consideration in the legislative process and remain unresolved. This applies in particular to the introduction and specific design of a cantonal property tax on owner-occupied second homes.

We'd be happy to keep you updated on further developments in both areas.

3. New rule for offsetting losses over a ten-year period

The period for offsetting tax losses will be extended from seven to ten years. Parliament passed the corresponding legislative amendment in December 2025. The referendum period expired on April 17, 2026, without any referendums being filed. The exact date of entry into force is still to be determined by the Federal Council, but will be no later than January 1, 2028.

The extended loss carryforward applies to both self-employed individuals for income tax purposes and legal entities for profit tax purposes. It covers the direct federal tax as well as cantonal and municipal taxes. The new ten-year period applies to tax losses incurred beginning with the 2020 tax period.

Companies with longer start-up, investment, or recovery phases benefit in particular from the extended carryover period, as losses can be offset against future profits over a longer period of time. However, carrying losses back to previous profitable years remains prohibited.

For losses arising from foreign permanent establishments as well, the relevant period for the subsequent offsetting of corresponding profits is extended from seven to ten years, provided the losses were incurred starting with the 2020 tax period.

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If you have any questions about these or other tax and legal changes, please feel free to contact us as usual.

Current Tax Developments: Individual Taxation, Elimination of the Imputed Rental Value, and New Loss Carryforward Period
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