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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

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