Undeclared income or assets: putting things right through voluntary disclosure
An account abroad that was never declared, an inherited flat, a side income left out. As long as the tax authorities do not know about it, the law lets you put it right without a fine, the first time.
The short answer
You tell the tax administration of your canton yourself what was not declared. There is then no fine and no criminal prosecution, on four conditions: a first disclosure, made before any tax authority knows of the evasion, unreserved cooperation in determining the back tax, and an effort to pay that back tax. The tax evaded, however, remains due: back taxes cover the periods not yet time-barred, i.e. up to ten years after the end of each tax period, interest included.Source: art. 175(3) DBG/LIFD, art. 56(1bis) StHG/LHID ; arts 151 and 152 DBG/LIFD, art. 53 StHG/LHID · checked on 12 October 2026
Key point: voluntary disclosure removes the fine, not the tax. It is only possible as long as the authorities do not know what you are disclosing.
What is the risk without a disclosure?
If the authorities discover the evasion themselves, they collect the same back taxes and add a fine: as a rule, the amount of tax evaded; down to one third for a minor fault, up to three times for a serious one; reduced to one fifth for a later disclosure that meets the conditions.Source: art. 175(2) and (4) DBG/LIFD · checked on 12 October 2026
What must be disclosed?
Everything that is missing, in Switzerland and abroad, whatever the amount: accounts and securities, real estate, shareholdings, loans granted, side income, and the income these assets produced. A partial disclosure does not meet the condition of unreserved cooperation.
An account abroad: is it too late?
For accounts and financial income covered by the automatic exchange of information: items covered by the automatic exchange of information are deemed known to the tax authorities as of 30 September 2018, or 30 September of the year of the first exchange for states that joined later; the canton decides whether a disclosure is voluntary. What it does not cover, real estate abroad for example, can still be disclosed. The cantonal administration decides whether the disclosure is voluntary.Source: Federal Tax Administration, AEOI and voluntary disclosures, 22.09.2026 · checked on 12 October 2026
You have inherited undeclared assets
Each heir can regularise what the deceased had not declared, independently of the others: each heir is entitled to it independently: back tax on the three tax periods before the year of death, with late-payment interest and no fine, as long as no authority knows of the evasion. It is best done early, since it is only open as long as the authorities do not know of the evasion.Source: art. 153a DBG/LIFD, art. 53a StHG/LHID · checked on 12 October 2026
What about a company?
the same regime applies to evasion within the business, filed by the company's officers or representatives; also possible after a change of name or of seat within Switzerland, a conversion, a merger or a demerger.Source: art. 181a DBG/LIFD, art. 57b StHG/LHID · checked on 12 October 2026
What a disclosure does not settle
It covers income and wealth tax, or profit and capital tax. VAT and the AHV/AVS contributions of the self-employed remain due, with interest. On withholding tax: the right to a refund is lost, unless the omission was due to negligence and the income is declared in an assessment, review or back-tax procedure not yet final.Source: art. 23 VStG/LIA · checked on 12 October 2026
The procedure, canton by canton
The rule is federal and the same everywhere. The form, the address and the documents required depend on the canton.
What we do for you
We reconstruct the years to be regularised, gather the documents, prepare the disclosure in the format your canton requires and handle your case through to the back-tax assessment. Before anything is sent, we check with you that nothing has been left out: an incomplete disclosure does not meet the conditions.
Checked on 12 October 2026.