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The capital tax is levied only at the cantonal and municipal level. As for the tax on profits, the cantonal prime rate is multiplied by cantonal and communal coefficients (or centimes). The basic rate is 0.06% in the canton of Vaud, 0.18% in the canton of Geneva and 0.075% in the canton of Zurich.
In most cantons, e.g. Vaud, Geneva, Bern or Thurgau, the capital tax is set off against the profit tax. This means that as soon as the cantonal and communal tax on profit exceeds the tax on capital, the latter is cancelled. Thus, as soon as the taxable profit exceeds 2% for the canton of Vaud, 7% for the canton of Geneva and 0.6% for the canton of Thurgau, the tax on capital is imputed. It should be noted that the imputation in Geneva will be done progressively in 25% increments to reach a full imputation as of 2025. Most Swiss cantons have already introduced this measure, with a few exceptions.
Secondly, although the RFFA abolished special tax statu(s), including the holding company status, which allowed the taxation of equity capital at a reduced rate, the RFFA leaves the possibility for cantons to provide a reduced rate for long-term loans, participations and patents. In essence, this means that companies whose main activity is to hold participations are taxed at a preferential rate. The rates vary greatly from one canton to another. Thus Geneva, which is one of the least attractive cantons in terms of capital tax for an ordinary company, is in fact one of the most attractive for holding companies.
