Abolition of the imputed rental value

On September 28, 2025, the Swiss electorate will vote on the abolition of the imputed rental value on owner-occupied properties.

We shed light on the specific voting question and explain in a factual and understandable way which aspects would change if it were accepted.

What we are voting on

On September 28, 2025, the electorate will vote on an amendment to the Federal Constitution. Specifically, they will decide on the introduction of the additional Art. 127 para. 2bis of the Federal Constitution (Federal Constitution of the Swiss Confederation). In order for the Federal Constitution to be amended, a majority of the people and cantons is required.

The voting question is: "Do you want to accept the federal decree of December 20, 2024 on cantonal property taxes on second homes?"

The abolition of the imputed rental value is linked to the constitutional amendment. If the vote is accepted, the imputed rental value will be abolished. If the vote is rejected, the imputed rental value tax will remain in place.

This would change

Imputed rental value

Income taxation of imputed rental value will no longer apply to all owner-occupied properties, both primary and secondary properties.

Debt interest

All private debt interest (e.g. mortgage interest, loan interest) is generally no longer deductible from taxable income. However, there is an exception if a property located in Switzerland is rented or leased out. In this case, the debt interest can be deducted pro rata in proportion to the value of this property to the total assets.

Another exception applies to taxpayers who acquire a permanently and exclusively owner-occupied property for the first time. In the first tax year after the purchase, the private debt interest attributable to this property can be deducted up to a maximum of CHF 10,000 (for married couples) or CHF 5,000 (for single persons). In the following ten tax years, the maximum deductible amount is reduced linearly by one tenth per year.

There is a transitional provision for taxpayers who acquired an owner-occupied property for the first time no more than ten years before the effective date. The above paragraph applies by analogy for the remaining tax years.

Maintenance costs

The actual and flat-rate maintenance costs for privately owned properties are no longer deductible. There is a possible exception at cantonal level for investments in energy-saving and environmental protection measures. While the following deductions will no longer be permitted at direct federal tax level in future, the cantons are free to decide in their respective legislation (optional provision) whether these expenses remain deductible or not.

  • Energy-saving and environmental protection measures
  • Dismantling costs with regard to a new replacement building
  • Deduction carried forward to the two subsequent tax periods

The deductibility of the costs of conservation work remains (direct federal tax) or depends on cantonal law (cantonal and municipal taxes).

In the case of rented or leased properties, maintenance costs are still deductible.

Special property tax

The adoption of the referendum allows the cantons to introduce a special property tax. Such a property tax only applies to secondary properties that are predominantly owner-occupied. Secondary properties that are predominantly rented out are not affected. Furthermore, owner-occupied residential property (main residence) is also not affected by such a property tax. Whether and how the cantons will implement the special property tax remains to be seen.

We are eagerly awaiting the result of the vote and are available for consultation both before and after the vote.

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Dennis Halders
Manager
Certified Tax Expert, Swiss Certified Fiduciary Specialist