In short
If you live in Switzerland, the income and value of an apartment in Georgia are not subject to Swiss tax: Swiss tax liability does not extend to real estate abroad (Article 6 of the Federal Direct Tax Act). They do, however, count towards the rate on your other income and wealth. That is why the apartment belongs in your cantonal tax return. Debts and interest are split between Switzerland and Georgia in proportion to your assets.
The principlesThis page gives no cantonal figures and does not replace tax advice. Your canton sets the rates and forms.
Inheriting property in GeorgiaLegal basis
The principles for people with unlimited Swiss tax liability, as of November 2026. The cantons apply them with their own rates and forms.
Unlimited tax liability does not extend to real estate abroad (Article 6(1) DBG), and the cantonal tax laws follow the same principle. Switzerland therefore exempts the apartment under its own law, regardless of the treaty.
The rate is set on your total worldwide income (Article 7(1) DBG). Income from the apartment in Georgia therefore raises the rate on your other income. The apartment's value does the same for cantonal wealth tax.
The treaty of 15 June 2010 (SR 0.672.936.01, in force since 7 July 2011) gives Georgia the right to tax the apartment's income, gains and capital value (Articles 6, 13 and 22). Switzerland exempts them and may apply the rate that would apply without the exemption (Article 23(2)).
Mortgages and other private debts are not allocated to a particular property but split between Switzerland and abroad in proportion to your assets. Part of your Swiss mortgage interest may therefore be allocated to Georgia and no longer reduce your Swiss income.
If you use the apartment yourself, its imputed rental value counts for rate determination until the end of 2028. On 1 April 2026 the Federal Council decided to bring the abolition of imputed rental value into force on 1 January 2029. The implementing rules will show how cantons treat foreign holiday homes after that.
In your return
The forms vary by canton, but the information they ask for is similar.
Enter the apartment with its address, year of purchase, value and income in the schedule of properties, marked as foreign. Convert dollar or lari amounts into francs as your canton specifies.
For rate determination, what counts is net income under Swiss law: rent less maintenance costs. A loss on the apartment is not deducted from your Swiss income but does count for the rate (Article 6(3) DBG).
The tax office splits debts and interest according to your assets. Keep records of the apartment's purchase price, value and financing to hand.
Switzerland does not tax a gain on selling the apartment, because foreign real estate is excluded. Georgia may tax it; after more than two years of ownership it is tax-free there.
Rates, valuation of foreign property, forms and inheritance and gift taxes are matters for the cantons. Ask your cantonal tax office or a tax adviser.
Frequently asked questions
Liability, rate determination, mortgage interest, imputed rent and the treaty.
Not directly. Foreign real estate is excluded from Swiss tax liability. Its income and value do count towards your rate, so the apartment belongs in your tax return.
Tax on your Swiss income is charged at the rate that would apply to your total worldwide income. The apartment in Georgia is not taxed itself but pushes the rate up. Wealth tax works the same way.
Not necessarily. Debts and interest are split between Switzerland and Georgia in proportion to your assets. The share that falls to Georgia does not reduce your Swiss income.
The Federal Council is bringing the reform into force on 1 January 2029. Imputed rent on owner-occupied homes then disappears and the related deductions are restricted. The federal and cantonal implementing rules will settle the detail for foreign homes.
Yes, signed on 15 June 2010 and in force since 7 July 2011 (SR 0.672.936.01). Georgia may tax the apartment's income, gains and capital value; Switzerland exempts them and applies progression.
Last reviewed on November 2, 2026. Sources: Federal Act on Direct Federal Taxation (DBG), Articles 6 and 7 (fedlex.admin.ch), Switzerland-Georgia double tax treaty of 15 June 2010, SR 0.672.936.01, Articles 6, 13, 22 and 23 (fedlex.admin.ch), Swiss Federal Tax Administration (estv.admin.ch): treaty with Georgia; change of system for homeowner taxation, Swiss Federal Tax Administration (estv.admin.ch), press release of 1 April 2026: Federal Council brings abolition of imputed rental value into force on 1 January 2029, Zurich cantonal tax office, Zürcher Steuerbuch no. 5.3: international tax allocation for real estate (zh.ch). This guide is not legal or tax advice.
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