29 September 2026

Ten years of loss carry-forward: Federal Council sets entry into force for 1 January 2028

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  • Taxes / Duties

Companies will be able to offset tax losses over a longer period. With this decision, the Federal Council provides greater planning certainty.

  • Dr. Samuel Bussmann

    Tax & Legal Partner

  • Christina Stocker

    Tax Counsel

  • Michael Widmer

    Junior Tax Consultant

From parliamentary decision to implementation

The period to offset losses will be extended, taking effect on January 1, 2028. Parliament had already passed the legislative amendment in December 2025, and the referendum deadline expired unused in April 2026. As reported in our article from April 29, 2026, this formally cleared the way for implementation, with only the exact effective date still pending. With the media release of 18 September 2026, the Federal Council has now completed this final step as well.

What will change?

The period during which tax losses can be offset against future profits will be extended from seven to ten years. This affects both direct federal tax as well as cantonal and communal taxes; cantons will need to adjust their legal provisions accordingly. In detail:

  • Extension to ten years: The new period applies to losses from tax period 2020 onward, for both self-employed individuals (income tax) and legal entities (profit tax). Losses incurred before 2020 remain subject to the previous seven-year period.
  • Losses from foreign permanent establishments: For direct federal tax purposes, Swiss companies and self-employed individuals can deduct losses of foreign permanent establishments from their domestic profits, provided these losses have not yet been taken into account for tax purposes abroad. However, this deduction is provisional: if the foreign permanent establishment generates profits within the following ten (currently seven) years that offset an earlier loss, Switzerland will reverse the deduction previously granted. As before, the cantons retain their own scope for regulating this matter.

Affected Tax-periods

Losses are assigned to a tax period based on the financial year's closing date, not the calendar year. If a financial year closes during the calendar year 2020, losses from as early as 2019 could already qualify for the new ten-year period.

What to do now

With the effective date now set, it is worth reviewing your tax position, including any implications for tax accounting.

Do you have any questions? Our tax team will be happy to assist you.

 
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