Switzerland intends to switch from joint spousal taxation to individual taxation. Anyone marrying, buying property or planning pensions now should keep the reform and its transitional rules in mind.
Switzerland currently taxes married couples jointly: incomes, assets and pension benefits are added and assessed together. Through progression, this often causes the so-called marriage penalty — married double earners pay more tax than unmarried couples with the same combined income.
The Federal Supreme Court already noted in BGE 110 Ia 7 (1984) that the extra burden on married couples conflicts with equal treatment. Politics has reacted: in 2024, Parliament adopted the cornerstones of individual taxation — implementation at federal and cantonal level is scheduled for 2027/2028. Status as of May 2026: federal act adopted, consultation closed, entry into force expected.
1. What is individual taxation?
With individual taxation, every person — regardless of marital status — is assessed as an autonomous tax subject. Spouses file separate returns, with their own income and asset share. Progression applies only to the individual income — the marriage penalty disappears.
Switzerland would not be alone: Germany, France (with 'splitting familial'), Austria, Sweden and many other EU countries have used individual taxation for decades. Within Switzerland, some cantons (e.g. Vaud with its 'splitting model') already operate hybrid solutions close to individual taxation.
2. What changes concretely?
Employment income
Instead of joint assessment, each person is taxed only on their own income. For double-earner couples, this practically always reduces the total tax burden — progression applies twice on flatter bases instead of once on a steep one.
Assets and asset returns
Under the new model, assets are split equally between the spouses — unless one demonstrates that the asset belongs solely to them. Equal splitting is intended to avoid administrative disputes.
Owner-occupied property and sales
Imputed rental value and property costs are split equally between spouses. On the sale of a property with a capital gain, the gain is allocated by halves.
Pensions
Pillars 2 and 3a remain individual — this was already the case. Deductions are made from each person's own income. Pension splitting on retirement (Art. 122 CC in divorce) remains untouched.
3. Winners and losers of the reform
The reform works asymmetrically:
• Double-earner couples with similar incomes: substantial savings (5–15% of total tax).
• Double earners with large income differential: medium savings.
• Single-earner couples (classical model): heavier load — the lower 'married' tariff disappears, full progression applies to the single income.
• Pensioner couples: minor changes, since pensions are already individual.
• Families with children: family deductions will be redesigned — either split or attributed to the main caregiver.
The Federal Department of Finance estimates the reform reduces federal and cantonal revenues by around CHF 1 billion in total — the money stays with taxpayers, mainly double-earner couples.
4. Transitional issues for 2026/2027
Anyone facing major decisions in the transitional period should check:
• Marriage contract: separation of property can become tax-advantageous because assets are then clearly individual.
• Real estate purchase in the transition: ownership shares should be chosen consciously — asymmetric participation can be tax-efficient depending on income split.
• Inheritance or gift: anyone receiving a larger estate should plan allocation in view of individual taxation.
• Salary optimisation: with flexible salary structures (self-employed, managing directors), the splitting between spouses is worth examining.
5. International aspects — spouses in different countries
In international configurations — e.g. one spouse Swiss-resident, the other EU-resident — Switzerland already applies de facto individual taxation because double-tax treaties recognise the residence country as the tax subject. The reform brings little change here. Different for Ukrainian-Swiss families with both resident in Switzerland — they will directly benefit or lose from the reform.
6. Pitfalls from advisory practice
• Late return adjustment at the switch — cantonal transitional periods will be tight.
• Missing documentation of asset origin — anyone who cannot prove individual property has it attributed by halves.
• Forgotten adjustment of powers of attorney and bank documents.
• Ambiguity on child deductions — either halved or fully with the main parent, depending on model.
• Pension planning — a 3a payment in the transition acts differently if the switch occurs in the next tax year.
7. What you can do today
Even though the reform is not yet in force, preparatory steps are worthwhile:
• Documentation of asset origin for both spouses (inheritance confirmations, gift contracts, purchase receipts).
• In larger property transactions, choose ownership shares deliberately.
• In salary structure of family businesses, examine splitting.
• Keep the ordinary tax return with all annexes clean — transitional data comes directly from these documents.
Practical note
Sobiera Legal Consulting supports double-earner couples, self-employed and family businesses with tax planning in view of individual taxation — in Ukrainian, Russian, German, English and French. Anyone buying a property, signing a marriage contract or making a major pension decision benefits from early structuring with the new tax regime in mind.