Switzerland: Swiss views on BEPS

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 views on BEPS

habermacher.jpg

reese.jpg

Hans Rudolf Habermacher


Markus Reese

The BEPS initiative attracts the attention of Swiss tax executives. The main reason is the uncertainty around the final outcome of BEPS and its impact on the international tax environment. Other reasons are the tight timeline for the implementation of BEPS and the immediate need for actions to mitigate tax risk exposure through an alignment of tax and operational models. From a Swiss tax perspective the complexity of the planned changes under BEPS is even greater since the Swiss government is currently working on the so-called Corporate Tax Reform III (CTR III) which aims to secure and strengthen the tax competitiveness and attractiveness of Switzerland as an international location for corporations. CTR III will replace current tax privileges, such as holding, mixed and domiciliary company tax regimes in the coming years with other measures, such as a License Box regime and the introduction of a notional interest deduction, in addition to a broad based reduction of headline cantonal tax rates, which is currently being discussed.

Measures proposed as part of the BEPS initiative obviously need to be taken into consideration when drafting the CTR III. It is the ambition to align the Swiss tax law with the internationally acknowledged OECD principles, especially from a transfer pricing point of view. It will make it easier for taxpayers in the future to defend the transfer prices applied between foreign and Swiss group entities if the business models are carefully aligned to the parameters of BEPS and CTR III. For multinational corporations which can demonstrate sufficient economic substance in Switzerland in particular, Switzerland will remain a preferred location for headquarter, principal, IP and financing structures.

Since the BEPS initiative by the G20 and OECD is still ongoing, the anticipated changes under CTR III are still to be determined. We will be closely monitoring the developments and shall keep you updated.

Hans Rudolf Habermacher (hhabermacher@deloitte.ch)

Tel: +41 58 279 6327
Markus Reese (mreese@deloitte.ch)

Tel: +41 58 279 6306

Deloitte

Website: www.deloitte.ch

more across site & shared bottom lb ros

More from across our site

Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts.
Brazil’s government has not officially framed the bill as a countermeasure amid trade tensions with the US, but the move is being considered as part of Brazil’s strategic response, one expert tells ITR
Understanding India’s income tax landscape can help charities ensure compliance, optimise tax benefits, and enhance their impact, writes Raghav Bajaj of Khaitan & Co
Tax advisers in Brazil are rising above the country’s notoriously complex tax system to deliver high-quality advisory services, ITR’s exclusive in-house data reveals
ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy
Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates
In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
In an exclusive interview with ITR, Ian Gary calls for a central public CbCR database and bemoans the US’s lack of involvement in international tax transparency
Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International
Gift this article