Does the Canton of Geneva have a step-up mechanism for SIALs?

Yes. The Canton of Geneva does not have a step-up mechanism for the sale of shares in real estate companies. The conditions are as follows:

• The sale resulted in taxation at a rate higher than 0% => capital gains subject to real estate profits and gains tax (IBGI);
• SIAL submits the request before the tax on the transaction becomes effective;
• The seller waives their right to tax confidentiality regarding their IBGI tax liability on the sale of the shares.

=> The deferred tax liability for cantonal and municipal taxes (ICC) at the SIAL level is eliminated to the extent of the capital gain actually subject to the IBGI (→ deferred tax liability recognized in its “tax balance sheet”).