The Swiss Parliament has approved an extension of the tax loss carryforward period from seven to 10 years. The 100-day referendum period expired on 17 April 2026, meaning there will be no public vote on the change and the measures are definitively adopted. The Federal Council will set the effective date at a later stage, but the amendment is expected to enter into force no later than 1 January 2028.
The main changes to the loss carryforward rules are as follows:
The broader carryforward window is intended to give taxpayers more flexibility in matching loss utilisation with future profitability.
Businesses will gain additional time to use tax losses, which may be particularly advantageous for businesses with longer investment, development or recovery cycles. Companies with unused tax losses from 2020 onward should evaluate how the extended carryforward period affects their tax planning, forecasting and cash tax profile. A review of existing loss positions may identify opportunities to optimise the use of future taxable income.
Jennifer Rothe
BDO in Switzerland
Key Changes
The main changes to the loss carryforward rules are as follows:
- The extension to a 10-year carryforward will apply for direct federal tax, as well as cantonal and communal taxes.
- The rules will apply to both legal entities and self-employed individuals.
- The rules cover tax losses arising from the 2020 tax period onward—other losses will continue to be subject to the seven-year carryforward period.
- The assessment period for recapturing profits from foreign permanent establishments, where prior losses were offset against domestic profits, will be extended in line with the new carryforward rules.
Practical Implications for Businesses
The broader carryforward window is intended to give taxpayers more flexibility in matching loss utilisation with future profitability.Businesses will gain additional time to use tax losses, which may be particularly advantageous for businesses with longer investment, development or recovery cycles. Companies with unused tax losses from 2020 onward should evaluate how the extended carryforward period affects their tax planning, forecasting and cash tax profile. A review of existing loss positions may identify opportunities to optimise the use of future taxable income.
Jennifer Rothe
BDO in Switzerland