Switzerland: New Swiss Principal Company and Swiss Finance Branch rulings to be phased out from January 1 2019

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: New Swiss Principal Company and Swiss Finance Branch rulings to be phased out from January 1 2019

Sponsored by

Sponsored_Firms_deloitte.png
There are many tax developments in indonesia

Switzerland is phasing out principal company and finance branch rulings as part of broader tax reform.

Switzerland is phasing out principal company and finance branch rulings as part of broader tax reform

From January 1 2019, no new rulings will be granted for Swiss principal company regimes that are governed by Circular Letter No. 8 (dated December 18 2001) and for Swiss finance branch regimes. Existing rulings for these regimes are scheduled to be sunset from January 1 2020 as part of broader Swiss tax reform.

The Sunsetting of Special Tax Regimes

The Swiss Federal Tax Administration (SFTA) on November 15 2018 announced that from January 1 2019, no new rulings for the Swiss principal company regime (governed under Circular Letter No. 8, dated December 18 2001) and for the Swiss finance branch regime, will be granted.

Existing rulings for these regimes are scheduled to be sunset from January 1 2020 as part of the Swiss Tax Reform and AHV Financing bill (TRAF, formerly Swiss Tax Reform 17), which was approved by the Swiss Federal Parliament in September 2018.

Under TRAF, all special tax regimes are scheduled to sunset January 1 2020 and be replaced with measures that are both internationally accepted and ensure Switzerland will remain attractive for multinational companies. However, the termination of the Swiss principal and the Swiss finance branch regimes - which are based on federal regulations, rather than tax law - do not require a legislative amendment. This is opposed to the abolishment of other special tax regimes, such as the holding and mixed company regimes.

Transitional rules

The statement by the SFTA does not include any comments making reference to the transitional rules for the Swiss principal company or Swiss finance branch regimes. The practice of a potential increase in the migration of principal business to Switzerland - upon implementation of TRAF - will be communicated once finally determined. However, we would expect that the determination would entail similar transitional rules to the mixed company regime.

Next steps

In line with Swiss legislative procedures, the final bill of TRAF is subject to a potential referendum (public vote). In order for such a referendum to be called, at least 50,000 voter signatures must be collected before the referendum deadline on January 19 2019. If a referendum is eventually called, a popular vote will be scheduled on May 19 2019. In case no referendum is called - or TRAF is approved by the popular vote in May - the Swiss Federal Council will enact all measures of TRAF, such as the sunset of all special tax regimes, as per January 1 2020.

This article was written by Jacques Kistler (jkistler@deloitte.ch) and Rene Zulauf (rzulauf@deloitte.ch) of Deloitte Switzerland.

more across site & shared bottom lb ros

More from across our site

The acquisition of a two-partner practice from Stephenson Harwood means that Charles Russell Speechlys has the largest private client team in Asia, the firm claimed
Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
Gift this article