This content is from: Switzerland


Switzerland is often discussed when the ethics of international tax competition are questioned, but recent events prove the country's willingness to adapt to the latest international standards.

However, as the landlocked country tries to adapt its tax system to meet its international commitments, the goal appears to be in direct conflict with its intentions to remain attractive to foreign investors. As Tax Partner AG – Taxand Switzerland's article indicates, the country is succeeding in both its objectives, however.

Burckhardt's article also touches on the country's ability to adapt to international influences while maintaining its reputation among big businesses as the place to locate key operations. The article looks at what the Swiss financial centre offers and how proposals to amend the Swiss Withholding Tax Ordinance will strengthen the financing activities of groups.

However, the onus for change is not always the responsibility of the government. ADB Altorfer Duss & Beilstein's article discusses how companies can voluntarily abandon a privileged tax status and move to ordinary taxation before a preferential regime is abolished.

Meanwhile, this guide also summarises the concept of substance in relation to tax matters. The term "substance" can have very different meanings and Deloitte discusses how it is of fundamental importance for the purposes of a substance-based analysis to avoid disputes – particularly those involving cross-border operations.

Laurent Lattmann & Désirée Högger of Tax Partner AG – Taxand Switzerland believe cross-border issues for companies are unlikely to go away soon. In their article, they discuss a recent VAT judgment issued by the Federal Administrative that will impact companies supplying goods to Switzerland.

However, it's not all bad news for companies. Many Swiss taxpayers, who were charged heavy amounts of late interest in relation to dividend payments, will benefit from a total repayment of CHF 600 million ($596 million) from the Swiss Confederation, writes Olivier Eichenberger of KPMG Switzerland.

We hope the fifth edition of this Switzerland guide provides useful insight as taxpayers seek to navigate a constantly-evolving landscape.

Anjana Haines
Editor, International Tax Review