
Swiss voters decisively rejected a proposal to introduce a federal inheritance tax at the end of November. A proposal initiated by the Socialist Youth party to impose a 50% federal inheritance and gift tax on wealth exceeding CHF50 million (USD61.8 million) was rejected by 78% of the electorate and all 26 cantons in a referendum.
It was the second attempt in recent years to introduce a federal inheritance tax. A previous initiative, which proposed a 20% tax on estates above CHF2 million, was also rejected by a significant margin of 71% in 2015.
With the initiative’s rejection, the current system remains unchanged. There is no federal inheritance or gift tax in Switzerland, but 24 Swiss cantons levy an inheritance tax and all of these except Lucerne also tax gifts. Only two cantons, Obwalden and Schwyz, do not tax either inheritances or gifts. Spouses and direct descendants are generally exempt or benefit from tax relief.
Also in November, the Swiss Federal Council approved amendments to the Ordinance on the International Automatic Exchange of Information in Tax Matters (AEOI Ordinance). These include provisions for revising the Federal Act on the International Automatic Exchange of Information in Tax Matters (AEOIA) to implement the OECD’s Crypto-Asset Reporting Framework (CARF) and the updates to the OECD’s Common Reporting Standard (CRS 2.0) within Switzerland’s domestic framework.
The Swiss National Council and the Council of States approved the extension of AEOI following its adoption by the OECD. This covers the update to the common standard on reporting and due diligence for financial account information (CRS 2.0) and the extension of the new.
The amended AEOI Ordinance introduces new obligations for crypto-asset service providers (CASPs) under CARF, including requirements for reporting information, conducting due diligence and registration. It also clarifies the nexus of CASPs with Switzerland.
CRS 2.0 will also now apply to associations and foundations, and their accounts, unless they meet certain exemption conditions. Transitional provisions are included to assist affected parties in implementing CRS 2.0 and CARF.
Both pieces of legislation are due to come into force on 1 January 2026, if no referendum is called during the review. But following the decision of the National Council’s Economic Affairs and Taxation Committee (EATC) to postpone the review of the draft legislation for activating the list of partner jurisdictions for CARF until next year, implementation is expected to be deferred until 2027 at the earliest.
