Switzerland: A closer look at notional interest deduction in the canton of Zurich

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Switzerland: A closer look at notional interest deduction in the canton of Zurich

Sponsored by

Sponsored_Firms_deloitte.png
NID was officially introduced into tax law on January 1 2020

René Zulauf and Loris Lipp of Deloitte explain why it would be worthwhile to analyse the application of notional interest deduction in the canton of Zurich.

Notional interest deduction (NID) was officially introduced into tax law on January 1 2020. The Swiss tax reform enacted then allowed cantons with a higher tax rate to apply the NID at cantonal and communal level. It is currently only being applied in the canton of Zurich.  

The NID qualifies as a tax-deductible expense for cantonal and communal taxes and is calculated by multiplying the so-called safety equity by the imputed interest rate.

Safety equity

Safety equity equals the difference between the total equity according to the Swiss statutory accounts and a minimum equity which is determined by applying a mechanical asset test (i.e. each asset on the balance sheet must be underpinned by a certain equity quota based on its average value during a business year and the resulting values are subsequently aggregated).

Imputed interest rate

For the sake of simplicity, the imputed interest rate shall equal the interest rate on a 10-year Swiss government bond. A variable interest rate may apply in line with the arm’s length principle on the safety equity attributable to intercompany receivables (i.e. including cash pool, short- and long-term receivables but exclusive of trade receivables).

Current environment

In the current interest rate environment, the NID provides a benefit mainly in cases where a company’s assets predominantly consist of intercompany receivables, such as in the case of finance companies or finance branches.

The NID should neither be qualified as harmful with regard to anti-hybrid mismatches (BEPS Action 2) nor as a tax practice itself (BEPS Action 5). Furthermore, the EU commission has recently closed the public consultation on the introduction of a debt-equity bias reduction allowance (DEBRA) for tax purposes and intends to adopt a respective directive, underpinning the general acceptance of the NID within the EU and probably the majority of the OECD, too.

For financing in the EU it may therefore be worthwhile to analyse the application of the NID in the canton of Zurich, particularly given that the EU commission has agreed to the introduction of an NID across the EU.

René Zulauf

Partner, Deloitte Switzerland

E: rzulauf@deloitte.ch 

Loris Lipp

Manager, Deloitte Switzerland

E: llipp@deloitte.ch

more across site & shared bottom lb ros

More from across our site

World Tax global head of research Jon Moore tells ITR how his team spots standout submissions, and gives early statistical insights into this year’s entries
Australia’s conservative opposition will repeal controversial tax agent reporting rules if elected in the country’s May general election
Shapley would be the fourth person to hold the job this year; in other news, UK tax advisory firm MHA raised fewer funds than expected from its London IPO
The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
The UK regulator is investigating EY’s auditing of the national postal service as it relates to the high-profile Horizon scandal, which saw hundreds wrongfully convicted
The directive will extend cooperation and information exchange around pillar two, according to the Council of the EU
Audit engagement partner Christopher Voogd has also been hit with a £32,500 charge over the firm’s work with Stirling Water Seafield Finance
China’s largest overhaul of its tax administration system in 24 years, featuring enhanced enforcement powers, is underway, says Abe Zhao of FenXun Partners
However, the US president increased tariffs on imported Chinese goods to 125%; in other news, UK tax firm MHA expects to raise £102m from its London listing
A mere three firms accounted for more than 90% of top-up taxes paid, according to research from Deloitte
Gift this article