Switzerland: A tonnage tax for maritime activities
International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX
Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Switzerland: A tonnage tax for maritime activities

Sponsored by

Sponsored_Firms_deloitte.png
The court had to decide on two separate questions

René Zulauf and Manuel Angehrn of Deloitte Switzerland look at how the federal government has planned to boost the country’s attractiveness as an international business hub for maritime activities.

Switzerland, located geographically in the heart of Europe, is associated with mountain peaks rather than a global maritime reach. However the country has one of the largest maritime merchant fleets in the world (11th in size globally, close behind the UK).

To strengthen the attraction of Switzerland to companies that operate and manage maritime activities, the Swiss federal government recently issued a consultation draft with regard to the introduction of a tonnage tax.

The proposed (simplified) law is that the taxable ‘profit’ of eligible companies would be based on cargo volume (net tonnage) rather than operating profits or volume of cargoes carried. The tax would be optional, and companies could choose instead to be taxed by existing methods.

It is considered that the tax would boost Switzerland’s attractiveness as an international business hub for maritime activities. This would help enlarge the shipping industry’s footprint in Switzerland. Further, the legislative draft provides incentives to modernise fleets and make them more environmentally friendly.

Eligible vessels and entities

  • Both corporations and individuals operating maritime vessels (freight and passenger), as well as special purpose vessels, would be able to apply for the tonnage tax; and

  • The taxable profit from operating and selling a vessel would be covered by the tonnage tax. Further, it would extend to profits from related activities on board a vessel, provided that these do not exceed 50% of the total profit from or of the vessel.

Requirements

  • At least 60% of the fleet (i.e. 60% of all ships owned and operated by the entity and subject to the tax) should be registered with the Swiss registrar; and

  • Taxation in accordance with the tonnage tax would be voluntary and would apply only on request from the taxpayer.

Determination of profit

  • The proposed draft would introduce a lump-sum tax on the profits attributable to maritime vessels, based on registered tonnage and days in use; and

  • Where vessels meet certain ecological requirements, particularly with regard to low emissions, a reduction of up to 20% would be available, based on criteria yet to be defined.

Though a legislative draft has been issued for consultation purposes, Switzerland is clearly taking a big step towards supporting an environmentally friendly shipping industry with an attractive taxation model.

Rene Zulauf

Partner, Deloitte Switzerland

E: rzulauf@deloitte.ch

 

Manuel Angehrn

Senior manager, Deloitte Switzerland

E: maangehrn@deloitte.ch



more across site & bottom lb ros

More from across our site

The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year
ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards
Global chair Mohamed Kande and Australian CEO Kevin Burrowes are likely to be grilled on the firm’s lack of co-operation
Consensus on the amount A multilateral convention will take more than six months to achieve, one expert believes
ITR is delighted to reveal all the shortlisted nominees for the 2024 Europe Middle East & Africa Tax Awards
ITR is delighted to reveal all the shortlisted nominees for the 2024 Asia-Pacific Tax Awards
There is a 'critical need' for a unified platform to address challenges in TP, the organisation’s president told ITR
Tax specialist Kate Barton helped to transform EY’s global tax practice, Dentons has claimed
Alex Gerko had challenged HMRC’s positions on deferred trading profits that he and other traders made while working for hedge fund GSA
The Tax Practitioners Board had required PwC to overhaul its internal processes following the tax leaks scandal
Gift this article