With the intention of making Switzerland more attractive as an international centre for finance and securities trading, the Swiss Federal Government proposes to abolish withholding tax on interest payments on Swiss bonds and also the securities transfer tax on trading in Swiss bonds and certain other debt instruments. At its meeting on April 14 2021 the government issued the formal dispatch in relation to these intended changes.
Switzerland currently levies withholding tax of 35% on interest on bonds issued in Switzerland and bonds issued abroad but reclassified as Swiss bonds. The respective withholding tax may be fully or partially reclaimed where a double taxation treaty applies.
The current withholding tax on interest of Swiss bonds has prompted many companies, foreign as well as Swiss, to avoid issuing bonds in Switzerland and to carry out their financing activities abroad. There is also currently a securities transfer tax of 0.15% on the value of Swiss bonds traded, which has driven trading in these bonds partly offshore: this tax will also now be abolished.
The Swiss government believes that these measures will, to a large extent, bring the issuance market for Swiss bonds as well as trading in Swiss bonds back to Switzerland.
There is also a view that these changes may persuade many foreign companies to establish financing activities in Switzerland, in order to benefit from the low income tax rates and the favourable Swiss tax environment in general.
We believe that the abolition of the withholding tax and the securities transfer tax on Swiss bonds will strengthen substantially the position of Switzerland as an international centre for finance and treasury. This has the potential to bring many finance and treasury-related jobs back to Switzerland, which should more than compensate over the longer term for the short-term drop in tax revenues.
René Zulauf
Partner, Deloitte Switzerland
E: rzulauf@deloitte.ch
Manuel Angehrn
Senior manager, Deloitte Switzerland
