Market overview

On June 17 2016, the Swiss Parliament approved the final bill of the Swiss Corporate Tax Reforms III (CTR III). The stated aim of the reforms is to bring Switzerland into line with international standards in key areas of corporate taxation. It is also intended to ensure that taxpayers can engage in effective international tax planning, maintaining Switzerland as an attractive place to do business even in a post-BEPS world.

Further, the government introduced a draft law on April 13 2016 based on Acton 13 of the OECD's BEPS Project. This introduced the requirement for Swiss-parented multinationals to submit country-by-country reports (CbCR) to the authorities for fiscal years starting on or after January 1 2018. Failure to do so could result in a fine of CHF 250,000 ($260,000).

The day before this draft law was published, the European Commission (EC) declared its intention to make it mandatory that CbCR be made public. If this comes to pass, it will be implemented in Switzerland through its obligations to the EU via the bilateral agreements it has in place.

Some taxpayers who value the confidentiality that incorporation in Switzerland has afforded in the past may see this as a deterrent to locating headquarters in the country. Advisers in the jurisdiction suggested that while this has been an influencing factor in some multinationals deciding to relocate, Switzerland otherwise remains attractive to foreign investment, meaning that the jurisdiction will continue to be competitive in the future.

Tax authorities

Federal Tax Administration
Federal Chancellery, Federal Palace West Wing, 3003 Bern
Tel: +41 58 462 21 11
Email: info@bk.admin.ch
Website: www.admin.ch

Tax rates at a glance

(As of January 1 2016)

Corporate income tax rate 11% - 24% (a)
Capital gains tax rate 11% - 24% (a/b)
Branch tax rate 11% - 24% (a)
Personal income tax rate (c)
22% - 48%
Withholding tax
Dividends 35% (d)
Interest n.a. (e)
Royalties from patents and licences n.a.
Branch remittance tax n.a.
Net operating losses (years)
Carryback Not allowable
Carryforward 7 years

  1. Combined federal/cantonal/municipal corporate income tax rate on profit before tax, depending on domicile, under reservation of privileged tax scheme (mixed companies 6%-10%).
  2. Higher rates may apply to real estate capital gains, depending on location of property.
  3. Combined federal/cantonal/municipal personal maximum income tax rate, depending on domicile.
  4. Under reservation of treaty tax reduction or full exemption under domestic law.
  5. Under reservation of interest paid by banks.

Source: Professionals from Tax Partner, Taxand Switzerland

Firm contact details

Loyens & Loeff