|Hans Rudolf Habermacher||Anja Klein|
The proposed tax reform may require taxpayers to pay more attention to their transfer pricing arrangements. This, however, may provide valid opportunities for companies to optimise their intercompany structures in such a way that they make maximum use of the new structuring possibilities. If implemented, an IP box tax exemption may allow existing companies to significantly reduce the tax rate on royalty income received from foreign affiliated companies or alternatively, a separate licence box company could be created to benefit from such an exemption.
Similarly, the notional interest deduction on equity as currently suggested would be an effective way to reduce a holding company's or mixed company's taxable income in case of a strong equity base. Thus, the new tax reform will allow taxpayers to implement attractive structures through valid transfer pricing, if aligned to the transfer pricing guidelines, as alternatives to the existing preferential Swiss tax regimes.
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