Switzerland: Swiss corporate tax reform to be subject to a referendum

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: Swiss corporate tax reform to be subject to a referendum

Sponsored by

Sponsored_Firms_deloitte.png
intl-updates-small.jpg

Switzerland's Tax Reform and AHV Financing Bill (TRAF, formerly known as Swiss Tax Reform 17 and Swiss Corporate Tax Reform III) will officially be subject to a referendum, as a largely left wing alliance made up of junior green and socialist parties has secured more than 50,000 signatures against the proposed law. The public vote is now scheduled for May 19 2019.

Sunset of all special Swiss corporate tax regimes

Under the reform, all special Swiss corporate tax regimes such as the mixed company, the holding company, the domiciliary company, the principal company (governed by Federal Circular Letter No. 8), and the finance branch regime, are likely scheduled to sunset from January 1 2020. These regimes will be replaced with measures that are both internationally accepted and that ensure Switzerland will remain attractive for multinational companies.

Transitional rules for sunsetting regimes

The sunset of these special tax regimes is subject to transitional rules. These rules should enable companies benefitting from such regimes to maintain their existing level of taxation by way of a special release of hidden reserves for another five years after the sunset of the regimes from January 1 2020, depending on their specific facts and circumstances.

Main replacement measures for corporate taxpayers

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

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

  • Introduction of a R&D super-deduction: at the cantonal level, up to a maximum of 150% of the effective qualifying expenses;

  • Step-up on 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 participations, patented intellectual property, and intercompany loans 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 additional selective cantons with high enough tax rates.

The bill is well supported by almost all of the relevant stakeholders ranging from business associations to unions and the whole political party spectrum, including the major left wing parties, who were formerly critical of the reform. We therefore currently deem the odds to be more likely than not that the bill will be confirmed in the public vote. However, the decision will be with the Swiss voter.

more across site & shared bottom lb ros

More from across our site

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four
As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
Gift this article