News on the changes in the valuation of securities without market value (participations)

News on the changes in the valuation of securities without market value (participations)
Nadja Haldimann-Good
The circular 28 on the valuation of participations undergoes a significant change. You can find out more about the tax consequences in this article.

Changes in the valuation of securities without market value (participations)


Circular 28 "Guidelines for the valuation of securities without market value for wealth tax" undergoes a significant change. According to a decision of the Swiss Tax Conference (SSK), the calculation of the capitalised earnings value for operating companies will be adjusted for balance sheet dates from 1 January 2021 (i.e. financial years ending in 2021). The capitalised earnings value generally forms the main basis for the wealth tax value and was previously calculated on the basis of the SWAP rate and had remained stable at 7% over the past years. It now represents a 3-year average of the three years preceding the assessment year and is composed of the risk-free interest rate, a risk premium and an illiquidity surcharge. For the year 2021, a capitalisation interest rate of 9.5% is calculated, which currently reduces the capitalised earnings value by 26.3% (change in capitalisation interest rate / new capitalisation interest rate).

The basis for the net asset value is still the annual financial statements under commercial law, taking into account certain tax adjustments (e.g. official value of the properties instead of book value) and before taking into account STAF-related additional deductions and / or disclosure of hidden reserves.

Canton of Bern

The Canton of Berne also adopts the adjustments described above, with the following additional specific adjustments: According to the practice of the Cantonal Tax Administration of Berne, for reasons of practicability, the previous year's tax value of securities without market value was used for the assessment of wealth tax, unless the taxpayer requested otherwise. While the 2019 taxable value was decisive in 2020, from the 2021 tax year onwards there will be a switch from the past to the present value as the taxable value. This means that the wealth tax value in 2021 must already be recorded in the 2021 tax return and forms the basis of the assessment in the current year.

Tax consequences

The shareholders and partners of participations in SMEs are primarily affected by the change. The higher capitalisation rate currently results in lower capitalised capitalised earnings values of 26.3%, which fundamentally reduces the enterprise value and thus the taxable assets. The higher the capitalised earnings value in relation to the net asset value, the greater the effective impact.


The following example shows the influence on the enterprise value and thus the tax value, which decreases by 15.5%:

The other side(s) of the coin

While a lower wealth tax value - in the above example around CHF 160,000 less than before - is basically good news for the annual tax return, this adjustment as well as the change in the canton of Berne affects strategic tax optimisation:

- Purchase price determination for succession arrangements, the pricing of which is based on the tax value in a simplified manner

- At best, a poor annual result in 2020, which is marked by the Corona lockdown, cannot be taken into account sufficiently due to the changeover that is now taking place.

In order to get the best out of these effects, which at first glance appear to be disadvantageous, both in terms of business management and taxation, we are happy to offer you our advice. Do not hesitate to contact us with your questions.

News on the changes in the valuation of securities without market value (participations)
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