Switzerland: Revised draft legislation on Corporate Tax Reform III introduced into parliament

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: Revised draft legislation on Corporate Tax Reform III introduced into parliament

kistler.jpg

zulauf.jpg

Jacques Kistler


Rene Zulauf

On June 5 the Swiss federal government introduced revised draft legislation on Corporate Tax Reform III (CTR III), which would sunset all special corporate tax regimes, such as mixed or holding company regimes. The draft legislation contains various measures to compensate for the elimination of beneficial tax regimes:

  • Reduction of headline tax rates on a cantonal/communal level at the discretion of cantons;

  • Introduction of a patent box applicable to patented IP for which the R&D spend occurred in Switzerland (in line with the OECD's modified nexus approach);

  • Introduction of excess R&D deductions at the discretion of cantons;

  • Allowing a step-up (including for self-created goodwill) for direct federal and cantonal/communal taxes upon the migration of a company or of additional activities and functions to Switzerland;

  • Tax privileged release of hidden reserves for cantonal/communal tax purposes for companies transitioning out of tax privileged cantonal tax regimes (such as mixed or holding companies) in a manner that this would reduce the cantonal/communal tax rate over a period of five years, such that in some cantons the previous tax privileged rate could be achieved for a period of five years.

  • Reduction of the cantonal/communal capital tax in relation to holding of participations and patented IP at the discretion of cantons;

  • Abolition of the 1% capital issuance tax on equity contributions;

  • Extension of the eligibility for foreign tax credits to Swiss permanent establishments of foreign entities.

The revised draft legislation is in some ways more attractive and in other ways more restrictive than the initial draft legislation introduced last year. CTR III is, however, still a work in progress and may change depending on the success of stakeholder lobbying.

The two-chamber Swiss parliament should vote on CTR III in autumn 2015 and spring 2016 respectively. There may also be a national referendum to allow the public to vote on the issue. Cantonal tax laws would subsequently have to be amended to reflect the changes, so that the most likely date for the law to become effective would be January 1 2019.

Jacques Kistler (jkistler@deloitte.ch) and Rene Zulauf (rzulauf@deloitte.ch)

Deloitte

Tel: +41 58 279 8164 and +41 58 279 6359

Website: www.deloitte.ch

more across site & shared bottom lb ros

More from across our site

The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
Businesses that adopt a proactive strategy and work closely with their advisers will be in the greatest position to transform HMRC’s relief scheme into real support for growth
The ATO and other authorities have been clamping down on companies that have failed to pay their tax
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Gift this article