Investing in foreign collective capital investment schemes (CCIS) in real estate, what is the tax implication for Swiss investors?

👉 One can hold a real estate investment directly («in their own name») or through a company (real estate company).

You can also hold a real estate investment through a PCC (collective investment scheme or other). In this case, when the PCC directly owns the properties, taxation does not occur at the investor level, but at the PCC level. What about foreign real estate PCCs?

👉 A foreign real estate CIV that directly holds properties is also taxed at the CIV level for the Swiss investor. There is therefore no taxation of the investor. This is all the more true when the CIV is subject to foreign supervision.

This solution is not only compliant with the law but also allows the investor to make their choice given the competitive neutrality at their level between a Swiss real estate SICAV or a foreign real estate SICAV.

The ruling is in German. It is a case from St. Gallen. Publication in the Federal Supreme Court decisions is planned.

Federal Tribunal, judgment 9C_757/2023, of 9 December 2024