Editorial

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Editorial

Using the tax system to attract investment into a country is nothing new. The UK has come under pressure over the lengths to which it is going to ensure potential foreign investors see it as "open for business", with the Patent Box regime coming under challenge and with claims the country is becoming a tax haven through its attractive controlled foreign company (CFC) rules and declining corporate tax rate. But if one country has been a trailblazer in this regard, it is Switzerland.

Switzerland was having its tax policies challenged by the EU when the UK's Patent Box regime was merely a twinkle in its implementers' eyes. Now, against a backdrop of international reforms and unprecedented levels of transparency and scrutiny of multinational tax affairs, in tandem with pan-European harmonisation measures, the scope for challenge of national regimes is increasing. Examples such as the US Foreign Account Tax Compliance Act, and the way in which it has been imposed on financial institutions and tax authorities around the world, highlight that outliers will no longer be tolerated.

With this in mind, Schellenberg Wittmer looks at what the international debate on tax transparency means for Swiss levels of information exchange.

Deloitte narrows that line of enquiry to focus on tax transparency trends in global banking and analyse how these patterns are likely to impact the Swiss financial services sector. Staying with FS, burckhardt explains the taxation of option rights granted to shareholders.

PwC tackles domestic reform, and looks in detail at specific measures including the proposed Licence Box for innovation and the notional interest deduction on surplus equity.

KPMG assesses the Swiss mobility challenge. Immigration changes are making it harder to enter the country while companies are having trouble convincing employees to leave the attractive working environment behind.

Distracted by attractive direct tax rules, potential investors in Switzerland often overlook indirct tax concerns. But here KPMG outlines advantages in the Swiss VAT system. The firm also identifies what impact OECD-level discussions on base erosion and profit shifting will have on the country, and provides a primer on taxpayer priorities when making acquisitions in Switzerland.

Many of these – mobility challenges, BEPS issues, increasing exchange of information – could be perceived as a threat to the position Switzerland holds within the international tax and finance framework, and that is precisely what Tax Partner – Taxand tackles in an article looking at the decisions that will be necessary to maintain competitiveness and attractiveness

Matthew Gilleard

Corporate Tax editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Following his Liberal Party’s election victory, one source expects Mark Carney to follow the international consensus on pillar two, as experts assess the new administration
A German economics professor was reportedly ‘irritated’ by how the Finnish ministry of finance used his data
Gift this article