---
name: ch-taxation-employee-stock-options-and-employee
description: "How employee shares, options, expectancies and phantom (non-genuine) participations are taxed and certified for Swiss direct federal tax purposes, for employers running a plan and for employees who hold one."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/ch-taxation-employee-stock-options-and-employee"
  jurisdiction: "CH"
  tax_year: "2026"
  last_updated: "2026-09-03"
  review_status: "pending_review"
---

# Taxation of employee stock options and employee participation plans in Switzerland

## Taxation of employee stock options and employee participation plans in Switzerland

This Guide covers the income-tax treatment of employee participations granted by an employer to an employee, and the certification duties that go with them, as set out by the Federal Tax Administration (ESTV) in Circular No. 37 on the taxation of employee participations (version of 30 October 2020) and in the Lohnausweis (salary certificate) documentation. It concerns the employer, who must value, certify and report the benefit, and the employee, who must declare it. Figures are for tax year 2026. The ESTV pages relied on below state the discount rule and the certification duties without limiting them to a named tax year; the salary-certificate FAQ used here is the ESTV version published for salary certificates from the 2026 tax period.

## Who this is for

Employers that grant employee participations and the people who receive them in an employment relationship. Circular No. 37 states that the following are **not** treated as employees for these purposes: entrepreneurs within the meaning of Art. 363 CO, mandataries, brokers and general agents within the meaning of Art. 394 ff. CO, and shareholders who are in no employment relationship. The Circular also covers the case where a Swiss parent company bears the costs of a seconded employee and thereby becomes the de facto employer. It does not settle cantonal tax rates or cantonal filing dates, and it expressly reserves diverging cantonal rules on how the certificate is delivered.

## Rates, thresholds and deadlines

**Discount rule and taxation point (mitarbeiterbeteiligungen source)**  _(https://www.estv.admin.ch/dam/estv/de/dokumente/estv/steuerpolitik/parlamentsgeschaefte/2-direkte-bundessteuer/2-13-mitarbeiterbeteiligungen.pdf.download.pdf/2-13-mitarbeiterbeteiligungen.pdf)_

| What | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://www.estv.admin.ch/dam/estv/de/dokumente/estv/steuerpolitik/parlamentsgeschaefte/2-direkte-bundessteuer/2-13-mitarbeiterbeteiligungen.pdf.download.pdf/2-13-mitarbeiterbeteiligungen.pdf |
| Discount on blocked employee shares, per blocking year | "Einschlag von jährlich 6 %" | Page's wording: the value of the shares is reduced by a discount of 6 % per year; the page adds that this restriction relevant to the tax base applies not only to direct federal tax but also in the cantons via the Tax Harmonisation Act |
| Maximum period over which that discount runs | "während maximal zehn Jahren" | Same sentence of the page; the page states the discount applies for a maximum of ten years |
| Taxation point for employee shares | at acquisition | Page's wording: for employee shares, taxation at the moment of acquisition is retained |

**Salary-certificate reporting (FAQ 2026 source)**  _(https://www.estv.admin.ch/dam/de/sd-web/36S9l-hXKaLr/dbst-form-lohna-faq-2026-de.pdf)_

| What | Value | Note |
| --- | --- | --- |
| Source | all figures below | https://www.estv.admin.ch/dam/de/sd-web/36S9l-hXKaLr/dbst-form-lohna-faq-2026-de.pdf |
| Salary-certificate field for income from employee participations | Ziffer 5 | FAQ: the entire income from employee participations is to be entered in Ziffer 5 of the salary certificate, and a certificate under the Employee Participation Ordinance (MBV) must be completed |
| Reporting where part of the income is allocated abroad | entire income still in Ziffer 5 | FAQ: even where part of this income has to be allocated abroad, the entire income must still be shown there; in an export case the employer must send the tax administration a certificate on the employee participation (Art. 8 MBV) |

## The method, step by step

- **1. Classify the instrument** — Determine whether the plan gives genuine employee participations (employee shares, expectancies on employee shares, employee options) or non-genuine ("unechte") participations. Circular No. 37 states that monetary benefits from the granting of non-genuine employee participations are taxable at the moment they accrue (Art. 17c DBG), that the entire monetary benefit is subject to income tax as earned income, and that consequently no tax-free private capital gain can arise from them.  _(https://www.estv.admin.ch/dam/estv/de/dokumente/dbst/kreisschreiben/dbst-ks-2020-1-037-d-de.pdf.download.pdf/dbst-ks-2020-1-037-d-de.pdf)_
- **2. Fix the moment of taxation and the valuation** — Circular No. 37 governs the moment of taxation in its section 3 and following, and for the conversion of foreign-currency values refers to the average closing bid/ask rate on the day of grant, of acquisition or of realisation of the monetary benefit, noting that in certain cases and in agreement with the competent tax authority a departure from this is possible. For blocked employee shares, apply the discount stated in the first table above.  _(https://www.estv.admin.ch/dam/estv/de/dokumente/dbst/kreisschreiben/dbst-ks-2020-1-037-d-de.pdf.download.pdf/dbst-ks-2020-1-037-d-de.pdf)_
- **3. Prepare the certificate under the MBV** — Circular No. 37 states that employers are in principle free in the design of the certificate, so long as it meets the minimum requirements of the MBV, and that model certificates are found in the annex to the Circular. The ESTV publishes those model certificates and worked examples as annexes, including the electronic model certificate.  _(Source (annex with model certificates): https://www.estv.admin.ch/dam/de/sd-web/OANb5cjm0TAe/dbst-ks-2020-1-037-d-anhang5-de.pdf and overview of all annexes: https://www.estv.admin.ch/de/kreisschreiben-direkten-bundessteuer)_
- **4. Deliver the certificate** — Circular No. 37 states that the employer must give the certificate to the employee as an annex to the salary certificate, or enclose it with the withholding-tax statement (Art. 10 MBV), and that diverging cantonal rules are reserved.  _(https://www.estv.admin.ch/dam/estv/de/dokumente/dbst/kreisschreiben/dbst-ks-2020-1-037-d-de.pdf.download.pdf/dbst-ks-2020-1-037-d-de.pdf)_
- **5. Send the certificate directly to the cantonal tax authority where required** — The Circular states that direct delivery to the cantonal tax authority of the employee's canton of residence is always necessary where the monetary benefit from employee participations is realised after the end of the employment relationship (Art. 15 MBV). It also describes the cross-border cases, in particular the employee moving from Switzerland abroad (Art. 8 MBV), where participations are granted in one country and realised in another, typically employee options, expectancies on employee shares or non-genuine participations.  _(https://www.estv.admin.ch/dam/estv/de/dokumente/dbst/kreisschreiben/dbst-ks-2020-1-037-d-de.pdf.download.pdf/dbst-ks-2020-1-037-d-de.pdf)_
- **6. Complete the salary certificate** — Enter the income from employee participations in the field named in the second table above and attach the MBV certificate for the tax year concerned, as instructed on the ESTV salary-certificate documentation.  _(https://www.estv.admin.ch/de/lohnausweis-rentenbescheinigung)_
- **7. Where a ruling is wanted, address the canton** — The ESTV states that the cantonal assessment authorities competent in the matter are responsible for granting a tax ruling in the field of direct federal tax, and that the ESTV gives information in this area only in the sense of an expert opinion for direct federal tax, referring to Circular No. 37.  _(https://www.estv.admin.ch/de/mitteilungen-estv)_
- **8. Filing and payment of the resulting tax** — The ESTV pages used for this Guide do not state a filing date or a payment date for the employee's cantonal tax return, nor cantonal tax rates. Those come from the employee's canton of residence and are outside these pages; this Guide states nothing for them.  _(The ESTV pages used for this Guide do not state a filing date or a payment date)_

## Ask the client first

- Is the instrument a genuine employee participation (shares, expectancies, options) or a non-genuine one, since the ESTV treats the latter as taxable at accrual with no tax-free private capital gain?
- Are the shares blocked, and for exactly how many years from which date, since the discount and its ten-year cap in the first table depend on the blocking period?
- Does the plan provide for early lapse of a blocking period on events such as early retirement, which Circular No. 37 treats in its worked examples as the conversion of still-blocked shares into unblocked shares?
- Was the employee resident or working outside Switzerland at any point between grant and realisation, which brings the import and export rules of the MBV into play?
- Will the benefit be realised after the employment relationship has ended, which triggers direct delivery of the certificate to the canton of residence?
- Who is the legal employer, and does a Swiss parent company bear the cost of a seconded employee so as to become the de facto employer?

## When to refuse or refer

- Cantonal and communal income tax rates, cantonal wealth tax valuations, and cantonal filing or payment deadlines: not stated on the ESTV pages used here.
- Cross-border allocation of the benefit between Switzerland and another state, and the withholding rate applied to a beneficiary resident abroad: the ESTV page consulted on this subject sets out the legislative proposals rather than a current rate card, so no figure is given here.
- AHV/social-security treatment of employee participations: outside the ESTV pages used here.
- Stamp duty questions: the ESTV notes that for a plan involving shares at preferential prices the turnover tax is owed only on the amount actually paid by the employee or deducted from salary, while the benefit granted is not its object; any plan whose stamp-duty treatment turns on the exemptions of Art. 14 StG should be referred, since this Guide states no figure for it.
- Valuation of unlisted or start-up shares and of options valued by formula: Circular No. 37 contemplates agreement with the competent tax authority, so obtain a cantonal ruling rather than relying on this Guide.
- Employer-side deduction for the cost of the plan: covered by a separate ESTV document, not by this Guide.

## Sources

- https://www.estv.admin.ch/dam/estv/de/dokumente/estv/steuerpolitik/parlamentsgeschaefte/2-direkte-bundessteuer/2-13-mitarbeiterbeteiligungen.pdf.download.pdf/2-13-mitarbeiterbeteiligungen.pdf (first table)
- https://www.estv.admin.ch/dam/de/sd-web/36S9l-hXKaLr/dbst-form-lohna-faq-2026-de.pdf (second table)
- https://www.estv.admin.ch/dam/estv/de/dokumente/dbst/kreisschreiben/dbst-ks-2020-1-037-d-de.pdf.download.pdf/dbst-ks-2020-1-037-d-de.pdf (method steps 1, 2, 4, 5)
- https://www.estv.admin.ch/dam/de/sd-web/OANb5cjm0TAe/dbst-ks-2020-1-037-d-anhang5-de.pdf (method step 3)
- https://www.estv.admin.ch/de/kreisschreiben-direkten-bundessteuer (method step 3)
- https://www.estv.admin.ch/de/lohnausweis-rentenbescheinigung (method step 6)
- https://www.estv.admin.ch/de/mitteilungen-estv (method step 7, stamp duty note)

Drafted by OpenAccountants. Not yet reviewed or approved by a named accountant.

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## Today's figures and who stands behind this skill

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