provident institutions and property gains

The exemption for provident institutions concerns direct taxes and inheritance and gift taxes, but not capital gains tax on property.

With regard to provident institutions which are exempt from income tax, the Geneva tax on property gains, calculated according to the property gains tax scale, is final. There is no need to subject the property gain to the income tax regime.

The judgment is in French (Geneva case). Publication in the Federal Supreme Court is planned.

Federal Tribunal, judgment 9C_393/2023, of 10 June 2024