Switzerland: Revised draft legislation on Corporate Tax Reform III introduced into parliament

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: Revised draft legislation on Corporate Tax Reform III introduced into parliament

kistler.jpg

zulauf.jpg

Jacques Kistler


Rene Zulauf

On June 5 the Swiss federal government introduced revised draft legislation on Corporate Tax Reform III (CTR III), which would sunset all special corporate tax regimes, such as mixed or holding company regimes. The draft legislation contains various measures to compensate for the elimination of beneficial tax regimes:

  • Reduction of headline tax rates on a cantonal/communal level at the discretion of cantons;

  • Introduction of a patent box applicable to patented IP for which the R&D spend occurred in Switzerland (in line with the OECD's modified nexus approach);

  • Introduction of excess R&D deductions at the discretion of cantons;

  • Allowing a step-up (including for self-created goodwill) for direct federal and cantonal/communal taxes upon the migration of a company or of additional activities and functions to Switzerland;

  • Tax privileged release of hidden reserves for cantonal/communal tax purposes for companies transitioning out of tax privileged cantonal tax regimes (such as mixed or holding companies) in a manner that this would reduce the cantonal/communal tax rate over a period of five years, such that in some cantons the previous tax privileged rate could be achieved for a period of five years.

  • Reduction of the cantonal/communal capital tax in relation to holding of participations and patented IP at the discretion of cantons;

  • Abolition of the 1% capital issuance tax on equity contributions;

  • Extension of the eligibility for foreign tax credits to Swiss permanent establishments of foreign entities.

The revised draft legislation is in some ways more attractive and in other ways more restrictive than the initial draft legislation introduced last year. CTR III is, however, still a work in progress and may change depending on the success of stakeholder lobbying.

The two-chamber Swiss parliament should vote on CTR III in autumn 2015 and spring 2016 respectively. There may also be a national referendum to allow the public to vote on the issue. Cantonal tax laws would subsequently have to be amended to reflect the changes, so that the most likely date for the law to become effective would be January 1 2019.

Jacques Kistler (jkistler@deloitte.ch) and Rene Zulauf (rzulauf@deloitte.ch)

Deloitte

Tel: +41 58 279 8164 and +41 58 279 6359

Website: www.deloitte.ch

more across site & shared bottom lb ros

More from across our site

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
Gift this article