Switzerland: Federal Council issues draft legislation on Tax Reform Proposal 17

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Switzerland: Federal Council issues draft legislation on Tax Reform Proposal 17

intl-updates-small.jpg
hess.jpg
zulauf.jpg

Jackie

Hess

René

Zulauf

On September 6 2017, the Swiss Federal Council issued the draft legislation for the Swiss Tax Reform Proposal 17 (STR 17, formerly known as Swiss Corporate Tax Reform III). The proposal that largely follows the recommendations of the steering committee represents a well-balanced and internationally competitive solution that would ensure that Switzerland stays an attractive location for multinationals and domestic companies alike, while at the same time providing an internationally aligned tax system that is in conformity with international standards, such as OECD BEPS and others.

The main proposed changes compared to CTR III include:

  • The notional interest deduction (NID) on federal and cantonal level is no longer part of the package;

  • The partial taxation for individual shareholders holding at least 10% would be increased to 70% from 60% on a federal level and mandatorily at least to 70% for all cantons; and

  • The combined tax relief for the patent box, the R&D super deduction and the amortisation from the step-up of hidden reserves due to a status change prior to STR 17 shall be limited to a maximum of 70% on a cantonal and communal level.

The main proposed elements of STR 17 include:

  • The sunset of all special corporate tax regimes, such as the mixed, domiciliary, holding and principal company regimes, as well as the Swiss finance branch regime;

  • The tax-privileged release of 'hidden reserves' for cantonal/communal tax purposes for companies transitioning out of tax-privileged cantonal tax regimes (such as mixed or holding companies) into ordinary taxation, with the intent to mitigate such effects by providing companies with a lower tax rate during a transition period of five years;

  • A reduction of the general cantonal/communal tax rates at the discretion of the individual cantons. Various cantons can be expected to be in the 12%–14% ETR bracket (effective combined federal/cantonal/communal tax rates);

  • The introduction of a mandatory cantonal-level patent box regime applicable to all patented intellectual property (IP) for which the research and development (R&D) spend occurred in Switzerland, based on the OECD modified nexus approach;

  • The introduction of cantonal R&D incentives in the form of deductions of up to 150% of qualifying R&D expenditure at the discretion of the individual cantons; and

  • A step-up of asset basis (including for self-created goodwill) for direct federal and cantonal/communal tax purposes upon the migration of a company or additional activities and functions into Switzerland.

Expected timeline

The proposed legislation will now enter the consultation procedure, which lasts for three months and under which the various stakeholders can weigh in on the legislation, so that the final version can be introduced into and voted on by the Swiss Parliament in its spring session of 2018. It seems currently unlikely that there would be a referendum (public vote) on the legislation, so that STR 17 could enter into force as soon as January 1 2020, but no later than January 1 2021.

Jackie Hess (jahess@deloitte.ch) and René Zulauf (rzulauf@deloitte.ch)

Deloitte

Tel: +41 58 279 6312 and +41 58 279 6359

Website: www.deloitte.ch

more across site & shared bottom lb ros

More from across our site

Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says
Mada has opened simultaneously in Paris and Dubai with an eight-lawyer team from Trinity International
PwC will continue to provide indirect tax services as part of the deal; in other news, the CJEU addressed the VAT treatment of TP adjustments
The arrival of Renan Ozturk and his team from A&M Tax introduces a unique proposition within the Middle East legal market, the firm said
The deal, reportedly worth $400m, will add Svalner Atlas’s 50-partner Nordic and Benelux presence to Ryan’s rapidly growing global footprint
The combined firm, which comprises over 1,400 lawyers, will boast robust tax practices in both the UK and US
Cascading tax reform, bullish foreign investment and vigorous TP audits have made Italy’s tax advisory market dynamic and stiffly competitive
As ITR data reveals that 2025 saw more than double the amount of private client hires than 2024, it seems firms are jostling for position
The US multinational paid 20% more tax in 2025 than 2024, it said; in other news, more than 25,000 HMRC staff have been upskilled on AI
Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
Gift this article