Switzerland: Swiss corporate tax reform 2017: Swiss Senate approves revised version of the reform

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Switzerland: Swiss corporate tax reform 2017: Swiss Senate approves revised version of the reform

Sponsored by

Sponsored_Firms_deloitte.png
intl-updates-small.jpg

On June 7 2018, the Swiss Senate passed the revised so-called Swiss Corporate Tax Reform 17 Bill following the recommendations of its Ways and Means Committee.

On June 7 2018, the Swiss Senate passed the revised so-called Swiss Corporate Tax Reform 17 Bill following the recommendations of its Ways and Means Committee. The version approved by the Swiss Senate contains the following elements.

Abolishment of all Swiss special income tax regimes

All special Swiss income tax regimes, such as the mixed company or holding company regimes, will be replaced with measures that are both internationally accepted and that ensure Switzerland will remain attractive for multinational companies.

Replacement measures

  • Reduction of the general tax rates at the discretion of the individual cantons, where the majority of cantons will be in the 13% to 14% tax rate range (effective combined federal/cantonal/communal tax rate, effective tax rate [ETR]) with some cantons, such as Zug, Schwyz and Lucerne, with an ETR as low as 12%;

  • Introduction of a patent box, which follows the so-called modified nexus approach by the OECD on a cantonal level with tax relief for qualifying income of up to 90%;

  • Introduction of a research and development (R&D) super-deduction at the cantonal level up to a maximum of 150% of the effective qualifying expenses;

  • Tax-privileged release of reserves for companies transitioning out of tax privileged regimes. This should enable companies to more or less maintain their existing level of taxation for another five years after the sunset of the regimes in 2019 or 2020;

  • Step-up upon migration of a company or of activities and functions to Switzerland. A step-up would be allowed for direct federal and cantonal/communal tax purposes (including on self-created goodwill) for companies or additional activities and functions migrating to Switzerland;

  • Reduction of the cantonal/communal annual capital tax in relation to intercompany loans and patented intellectual property at the discretion of the individual cantons; and

  • Cantons with a 'high' cantonal tax rate may introduce a notional interest deduction (NID) on a cantonal level. This may only benefit the canton of Zurich and potentially very few selective cantons with high enough tax rates.

Revenue raising measures

The Bill contains the following revenue raising measures:

  • Listed companies, when repaying qualified capital contribution reserves (which can be repaid tax free), must now pay at least an equal amount in dividends;

  • The partial taxation of dividends for qualifying Swiss shareholders is increased to 70% at a federal level, respectively to at least 50% at a cantonal level; and

  • The tax reform will be combined with Swiss social security reform, with an increase of social security contributions by employees and employers.

Next steps

The Swiss House of Representatives is expected to vote on the legislation in its autumn 2018 session. The final reform is expected to pass by September 2018.

If there is no referendum, some elements of the tax reform, such as the automatic termination (sunset) of regimes with respective transition measures could become effective as soon as in the first quarter of 2019, with the bulk of the reform being effective as early as January 1 2021.

more across site & shared bottom lb ros

More from across our site

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity
Tax professionals are still going to be needed, but AI will make it easier for them than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR
AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
Taylor Wessing, whose most recent UK revenues were £283.7m, would become part of a £1.23bn firm post combination
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap
An EY survey of almost 2,000 tax leaders also found that only 49% of respondents feel ‘highly prepared’ to manage an anticipated surge of disputes
Gift this article