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.
(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%|
|Royalties from patents and licences||n.a.|
|Branch remittance tax||n.a.|
Net operating losses (years)
Source: Professionals from Tax Partner, Taxand Switzerland