Taxation and artificial intelligence in Switzerland : toward a new fiscal model for intelligent robots?
The rise of artificial intelligence (AI) and so-called “intelligent” robots is disrupting the traditional framework of Swiss tax law. Built on the taxation of natural and legal persons, the current fiscal system now faces the growing presence of technological systems capable of replacing human labor.
A Changing Swiss Landscape
As a service- and innovation-driven economy, Switzerland is directly exposed to digital transformation. The integration of AI into public administration and private enterprises requires a redefinition of key concepts such as labor, income, and tax capacity. This raises significant challenges: erosion of income tax revenues from individuals, potential rise in technological unemployment, and increased pressure on social insurance systems.
Toward a New Category of Taxpayers?
At present, only natural and legal persons are subject to taxation. The question arises whether a specific fiscal status should be created for robotic entities: could autonomous systems that generate economic resources be taxed? Even without granting them legal personality, a tax obligation could be justified based on the principle of economic capacity—a central concept in Swiss tax law.
Exploring Targeted Taxation Models
Inspired by international debates (e.g., EU, South Korea), a taxation framework for robots could take several forms:
➤ Usage or equipment tax, based on the value or frequency of robot use (similar to vehicle taxation);
➤ Automation surtax, linked to the ratio between revenue generated and human jobs replaced;
➤ AI ownership or income tax, akin to a royalty or withholding tax;
➤ Tax incentives for human employment, through deductions or tax credits;
➤ Funding a basic income, in response to large-scale automation.
Conclusion
Switzerland, with its strong tradition of innovation and stability, is well-positioned to lead a tax reform tailored to the digital economy. This reform will need to balance technological neutrality, fiscal fairness, and economic attractiveness. Far from being a theoretical exercise, adapting Swiss tax law to the age of AI is becoming a legal, economic, and social imperative.
Article written by Me Lassana Dioum