Switzerland: Update on corporate tax reform legislation

Switzerland: Update on corporate tax reform legislation

The Swiss Council of States on 14 December 2015 discussed proposals for corporate tax legislation known as “Corporate Tax Reform III.”

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Switzerland, in making changes to its corporate tax law, may repeal certain privileged tax regimes—for example, the holding, domiciliary and mixed company at cantonal / municipal level and the “principal company status” at the federal level. Further, the Swiss finance branch / company regime will cease to exist. 

Several measures have been proposed in order to mitigate or ease the effects of repeal of these pivileged regimes.

Patent box, R&D measures

The small chamber of the Swiss parliament concluded that:

  • A “patent box” regime would be introduced and is expected to result in an effective tax rate of approximately 10% on patent-related income.
  • The Swiss cantons would be allowed to introduce a research and development (R&D) “super deduction” that would not be greater than 150%.
  • Transitional measures for the “step-up” for tax purposes would help companies absorb the fiscal shook of a sudden increase of their tax burden.

Items rejected

The small chamber voted against: 

  • Repeal of the stamp issuance duty (tax) of 1% 
  • Allowing the cantons to revise the rules for reduce taxation of dividends 
  • Allowing a “notional interest deduction”

What’s next?

The reform package is expected to be discussed in the large chamber in early 2016, with the legislation to be enacted and effective in January 2017—but it is possible that with a highly likely event of a referendum being held, the effective date could be delayed to sometime in 2018 or 2019. The cantons generally have two years in which to amend cantonal legislation. During that two-year period, according to the federal tax administration, the “principal status” as well as the finance branch / company regime would continue to apply.


Read a December 2015 blog posting by the KPMG member firm in Switzerland: Corporate Tax Reform III: Council of States took position

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