Published by Citywealth, 11 November 2026 – on individual taxation, the marriage penalty and Switzerland’s new beneficial ownership register
Switzerland is rewriting two rulebooks at once. From 1 January 2032, spouses will be taxed as individuals, removing the Swiss marriage penalty from the statute book. And since 1 October 2026, companies and trustees have had to report their beneficial owners to a new federal register. Both changes reach private clients at the same time.
The analysis comes from Citywealth’s Swiss Private Wealth Update 2026 by Karen Jones. It draws on commentary from Dr Ariel Sergio Davidoff, founding partner of Davidoff Law in Zurich, alongside advisers in Geneva, London and New York. It follows our earlier Swiss private wealth update.
Individual Taxation Ends the Swiss Marriage Penalty
On 8 March 2026, 54.23 per cent of voters approved the Federal Act on Individual Taxation. Each spouse will file a separate return and be taxed on their own income and assets, at the federal, cantonal and municipal levels alike.
The reason is arithmetic. Today, spouses’ incomes and assets are added together. Under progressive rates, that pooling can leave a married couple paying more than an unmarried couple earning exactly the same. The wedding, as Dr Davidoff puts it, came with an uninvited guest whose congratulations included a request for a cheque.
“Swiss couples are heading for a separation, at least on paper.” – Dr Ariel Sergio Davidoff
A Second Vote on 29 November 2026
The matter is not closed. On 29 November 2026, voters decide on a constitutional initiative that would keep joint assessment for the direct federal tax while prohibiting tax disadvantages for married couples. It requires a majority of both voters and cantons, and Parliament recommends rejection.
If it is accepted, couples could remain jointly assessed for federal tax but be taxed separately at the cantonal and municipal level from 2032, unless Parliament legislates again. Families planning towards 2032 should treat the direction as settled and the detail as open.
The New Federal Transparency Register
The second change is already in force. Since 1 October 2026, the Federal Act on the Transparency of Legal Entities requires Swiss companies limited by shares, limited liability companies, cooperatives and comparable entities to identify their beneficial owners and report them centrally. Foreign entities are covered if they have a Swiss branch, are effectively managed from Switzerland, or own Swiss real estate. Trustees with a Swiss office are covered too, unless they are already subject to the Anti-Money Laundering Act.
A beneficial owner is always a natural person who ultimately controls an entity or takes its economic benefit, as a rule from 25 per cent of the capital or voting rights, or through control exercised in another way. Intermediate entities in the ownership chain must be reported as well. Dr Davidoff describes this as an ongoing federal reporting duty rather than an internal record-keeping exercise: entities should trace their ownership chains now, retain the supporting documents and build a process for reporting changes.
First reports fall due between 31 December 2026 and 31 March 2027, depending on legal form and audit status, or within two years where all beneficial owners already appear in the commercial register. Any change to the commercial register brings the deadline forward to one month, and later changes are reportable within one month. Fines reach CHF 500,000. The register is not public: access is limited to the control office and the authorities named in the Act, and to intermediaries and advisers subject to the Anti-Money Laundering Act for due diligence purposes.
Expanded AML Duties for Advisers
The revised Anti-Money Laundering Act entered into force on the same day. It extends due diligence duties to lawyers, notaries, fiduciaries, and tax advisers who assist with listed transactions, including setting up, administering, or funding a company, foundation, or trust. The thresholds are low: in a calendar year, fees above CHF 50,000, more than 20 clients, assets above CHF 5 million or transactions above CHF 2 million. Litigation stays outside. Advisers already carrying on such work must apply to a self-regulatory organisation by 1 December 2026.
Taken together, the two reforms point the same way. Swiss private wealth planning now depends as much on documented ownership and defensible process as on the choice of canton. Similar themes run through our notes on cross-border transactions and the Berne Agreement BFSA.
Davidoff Law advises entrepreneurs, investors and entrepreneurial families in Zurich on Swiss tax, structuring, relocation and reporting duties.
Read the full Citywealth article here: Swiss Private Wealth Update 2026: Beneficial Ownership Register, Expanded AML Rules and Tax Reforms
