Editorial

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

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

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
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
Gift this article