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

New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Gift this article