Zinssätze die seit 18.12.2024 gelten

The private foundation is an established instrument for asset management. As an ownerless legal entity, it allows for the binding of assets for a defined purpose and protects them from fragmentation. Starting from January 1, 2026, tax increases will apply.

The taxation of private foundations occurs on three levels (entry taxation, ongoing taxation, exit taxation). When assets are contributed to a private foundation, foundation entry tax is incurred. The basis for the foundation entry tax is usually the fair market value. If real estate is contributed, it is exempt from entry tax; instead, it is subject to an increased property transfer tax (equivalent to foundation entry tax).
The foundation entry tax currently amounts to 2.5% (for the year 2024) and will be raised to 3.5% effective from January 1, 2026. The so-called foundation entry tax equivalent (i.e., increased property transfer tax) will also be increased from 2.5% to 3.5% from January 1, 2026, resulting in a total property transfer tax on contributions of real estate rising from 6% to 7%.

Increase in intermediate tax

A private foundation is subject to corporate income tax as a legal entity. Most income, such as income from agriculture and forestry, business operations, or rental and leasing, is subject to the regular 23% corporate income tax rate. Other income, particularly domestic and foreign bank interest, gains from the sale of securities, and other realized capital gains as well as property sales of private assets, are subject to the so-called intermediate tax. The intermediate tax should be understood as a "pre-taxation." Contributions from a private foundation to domestic beneficiaries reduce the interim taxable income for the year. If the contributions exceed the intermediate taxable income of a year, a credit of the intermediate tax paid in previous years, which has been recorded in an evidence account, will also occur.
Since 2024, the intermediate tax is set at 23% (24% in 2023). This will be increased to 27.5% starting from the calendar year 2026. Contributions from private foundations to beneficiaries will also continue to be subject to the 27.5% capital gains tax from January 1, 2026, which must be withheld by the private foundation at the time of receipt and remitted to the tax office. Such contributions can still reduce the basis for the intermediate tax.

Tip
Due to the increase in the foundation entry tax from January 1, 2026, contributions to private foundations will be more heavily taxed in the future. If contributions to private foundations are planned, it is advisable to plan early to make the contributions in the year 2025.