Switzerland: Swiss CTR III - Latest draft legislation issued by the Federal Council

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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


Switzerland: Swiss CTR III - Latest draft legislation issued by the Federal Council

zulauf.jpg

weder.jpg

Rene Zulauf


Diego Weder

Overall the draft legislation (released after public consultation) for Switzerland's Corporate Tax Reform III (CTR III) remains very attractive, in particular given the following favourable developments as compared to the original proposal:

  • The proposed introduction of a capital gains tax for individuals was dropped;

  • The draft legislation will newly introduce some sort of R&D incentives, which were not in the original proposal, in addition to the patent box regime;

  • The so-called step up for tax purposes that would essentially lead to a grandfathering of the effective tax rates of existing cantonal tax regimes that sunset as part of the tax reform presumably in 2019 or 2020, for many years should now be structured in such a way as also to provide a financial statement benefit, that is, for US GAAP and IFRS purposes, not just for cash tax purposes; and

  • The planned abolition of the 1% capital issuance tax on equity contributions was confirmed.

The proposed peripheral measures that were dropped, such as the change of the participation regime, were not necessarily favourable to the taxpayer and did not find enough support.

The one negative development is that the notional interest deduction (NID) on equity was dropped. Without this NID regime Switzerland would no longer be attractive for financing activities. Accordingly, a lobbying effort can be expected to bring this regime back into the legislation.

The main replacement measures for the tax regimes that sunset in 2019 or 2020, depending on the time needed for the legislative process, are:

  • Step-up for tax purposes;

  • Patent box; and

  • General tax rate reduction.

Although a public vote on the legislation by the Swiss voters is likely, we are confident that the legislation would pass such a referendum.

Rene Zulauf (rzulauf@deloitte.ch) and Diego Weder (diweder@deloitte.com)

Deloitte

Tel: +41 58 279 6359 and +1 917 573 6783

Website: www.deloitte.ch

more across site & shared bottom lb ros

More from across our site

The ambitious big four challenger firm has also appointed ex-RSM partner Brad Ashton to build out its customs and global trade practice
The big four firm allegedly reviewed backdated documents and signed off on accounts that removed hundreds of millions of dollars of Abramovich’s assets
New Tier 1 entrants and an expanding cohort of established players indicate that law firms are becoming increasingly credible challengers in Europe's TP market
Awards
Leading firms and individuals gathered in Dubai to celebrate standout legal, dealmaking and tax work across the region
Tax authorities want more revenue, have better tools to find it and are increasingly willing to fight for it
Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for
The deal for Comtax hands Ryan immediate scale in Brazil, with a near-70-strong team serving clients from São Paulo
The arrivals of Julio Castro and Adam Blakemore mean the firm has added six tax partners to its global practice since the start of 2025
Tax authorities have gained unprecedented transparency through CbCR, but a new study suggests they may not be looking in the right places
Gift this article