On January 10 2018 the Swiss finance minister provided an update on the timeline for the implementation of STR 17.
A quick and business-friendly implementation of STR 17 would help to ensure that Switzerland remains a major player in the international tax arena. Under the envisaged timeline the first measures of STR 17 could come into effect at the start of 2019, with the main part of the reform coming into effect by 2020.
The STR 17 will provide for the sunset of all special corporate tax regimes, such as the holding or mixed company tax regimes, and will replace them with other measures, such as the introduction of a patent box, a super research and development deduction, or a substantial reduction of headline tax rates at the discretion of individual cantons. Most taxpayers with special corporate tax regimes should thereby effectively benefit from a transition period of five years as from the implementation of the reform.
The push for lower tax rates globally, and in particular the recently enacted very business friendly US tax reform, has put more pressure on the need for a timely implementation of STR 17. This is clearly recognised by the Swiss federal government and all stakeholders in the political consultation process for the reform, such as the cantons and business and labour representatives. The STR 17 is thereby seen as an effective measure for Switzerland to remain competitive as a location for multinationals and domestic businesses alike, which should enable Switzerland to continue to attract multinational companies with high quality jobs.
Despite the pressure for a quick and business friendly implementation of the reform, the so-called consultation process revealed that a well-balanced corporate tax reform, which will take into account the concerns of all stakeholders, will be needed to find sufficient support in the Swiss Parliament and in particular to avoid a subsequent referendum.
The envisaged timeline is that some of the STR 17 measures will be enacted as soon as the beginning of 2019, with the bulk of the measures expected in 2020.
The Swiss Federal Department of Finance (SFDF) has announced that it will submit the dispatch for STR 17 for the attention of the Swiss Federal Parliament to the Federal Council in spring 2018. The Swiss Parliament should thus be able to finally agree on the tax reform in its autumn 2018 session. According to the SFDF, the first measures of STR 17 could come into force at the beginning of 2019, while most of them could come into force by 2020. Measures that could be implemented as soon as at the beginning of 2019 would in particular be those which are mandatory for all cantons and could be implemented via the Federal Tax Harmonisation Law.
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