Switzerland and OECD pillar two: Redefining taxes, charges and duties
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 and OECD pillar two: Redefining taxes, charges and duties

Sponsored by

Sponsored_Firms_deloitte.png
From 2022 new tax incentives will come into force in both Polish corporate and personal income tax

René Zulauf and Manuel Angehrn of Deloitte Switzerland explain why Switzerland remains open for global business.

The G20/OECD project to introduce a global minimum tax level of 15% is taking shape and moving forward fast, and country responses are progressing slowly. 

The Swiss federal government has given the Swiss Federal Tax Administration and the cantonal tax authorities the task of elaborating, in collaboration with interest groups from all Swiss economic sectors, possible Swiss responses. 

The OECD technical guidance on income inclusion rules and undertaxed payments, which will be published later in 2021, must be translated into Swiss law. The Swiss Parliament meanwhile has tasked the government with other tax reforms:

  • The global anti-base erosion (GloBE) rules require affected corporations to achieve jurisdictional minimal taxation of 15% in order to avoid a top-up tax. All covered taxes can be counted towards the 15% tax due and ordinary tax rates on affected corporations may need to be increased. Parliament requests that these increases are based on a ‘cost-neutral’ approach for affected corporations. As such, charges and duties, which are not considered covered taxes, should be reduced accordingly.

  • Lowering the administrative burden on Swiss corporations with regard to their financing needs, in particular with regard to the abolition of Swiss withholding taxes on all financing issued from Switzerland, enjoys broad-based agreement in Parliament. Legislation is expected to be passed in the course of this year.

  • Abolition of Swiss stamp duties is a further proposal that goes beyond the proposed adjustments to Swiss withholding taxes. The related law passed through Parliament in June 2021 and may, unless a referendum is called, enter into force as soon as 2022.

The global tax environment is changing fast and Switzerland is working quickly to innovate its tax landscape and remain attractive. 

Given the broad range of tax reforms and the country’s intention to make the changes to taxes, charges and dues as cost-neutral as possible for corporations, Switzerland remains open for global business.

 

René 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

Proposals by HM Revenue and Customs to raise standards in the advisory market are ‘well overdue’, one partner declared
An intimate understanding of a client’s sector is essential to winning new business, a survey of over 28,000 corporate counsel reveals
‘Auditors are failing to perform their core function’ according to a think tank; in other news, White & Case adds a tax partner in Luxembourg
An overhaul of EU import taxes could spell the end of an exemption for cheap parcels
Sharma, managing director for A&M in the United Arab Emirates, tells ITR about intense time pressures, mimicking Jurgen Klopp and what makes tax cool
AI will speed up some of the most laborious TP processes without making human input redundant, argues Hank Moonen, CEO of TaxModel
Firms with a broad geographic reach are more likely to win work, especially from global companies with high turnovers, according to survey data of nearly 29,000 corporate counsel
Australian businessman Gordon Merchant used EY’s advice to offset an A$85 million capital gain, according to the Federal Court
Griggs has been drafted in ahead of schedule as the incumbent Tim Ryan departs for Citigroup; while the Netherlands plans to scrap a 15% share buyback tax
Authorities must ensure that Russian firms do not use transfer pricing schemes to increase profits made from oil sold in different markets, advocacy organisations have argued
Gift this article