⏱ 2 min 30 read
Background
Many Geneva residents own property in France through a société civile immobilière (SCI), a French real estate company. Until now, the Geneva cantonal tax administration often treated these shares as foreign property, and therefore exempt from wealth tax in Geneva. A Federal Supreme Court ruling of 13 December 2022 called this practice into question. According to KPMG, it confirmed the Vaud practice and required a change in Geneva.
The key points
The Canton of Geneva clarified its new practice in 2026, according to a note published by the firm KPMG. Shares in French SCIs are now considered movable assets, in the same way as shares or bonds, the State of Geneva's official website states.
The double taxation treaty between Switzerland and France still applies. If the SCI is already subject to the French real estate wealth tax (IFI), Geneva only uses its value to set the tax rate. If no IFI is due, the full value of the SCI becomes taxable in Geneva as wealth.
The shares are valued at their net asset value, in line with Circular 28 of the Swiss Tax Conference (CSI). Taxpayers concerned must attach a specific SCI annex to their tax return. According to KPMG, the administration has started sending information requests to SCI holders.
Key figures
- 1.3 million euros: net real estate wealth threshold below which no IFI is due in France (KPMG)
- 2024 and 2025 : tax years currently covered by the SCI annex (KPMG)
- 13 December 2022 : date of the Federal Supreme Court ruling behind the change
What it means for businesses
- Geneva-resident executives with an SCI in France : possible increase in taxable wealth if no IFI is levied
- Fiduciaries and tax advisers : SCI annex to complete, with French tax documentation (SIREN number, assets, debts, ownership shares)
- Open tax files : the new practice may apply to assessments that are not yet final, according to KPMG
Analysis
- According to KPMG, this is a substantive change for taxpayers who reported their shares as foreign property; the firm recommends an inventory of their SCIs and a case-by-case review
