Switzerland: Swiss cantons announce lower headline tax rates in anticipation of Swiss Corporate Tax Reform III

Jackie Hess		Jacques Kistler

Switzerland is contemplating a comprehensive corporate tax reform – Swiss Corporate Tax Reform III – which would phase out certain tax regimes, such as the holding, mixed and domiciliary company regimes in the 2018 – 2020 timeframe and replace these regimes with a variety of other measures. The overriding objective of this comprehensive tax reform is to secure and strengthen the tax competitiveness and attractiveness of Switzerland as an international location for corporations.

Several measures to replace the holding, mixed and domiciliary company regimes that would accomplish the dual goals of tax competitiveness and international acceptance are being considered, in particular:

• A licence box for income arising from the exploitation and use of intellectual property;

• A notional interest deduction on equity; and

• A general reduction of the headline corporate tax rate (effective combined federal/cantonal/communal rate).

Twelve Swiss cantons are now considering a reduction of their headline tax rate (effective combined federal/cantonal/communal rate). The following cantons already announced a reduction of their headline corporate tax rates: Vaud to 13.8%, Geneva to 13%, Neuchâtel to 15.6%, Fribourg to 15%, and Zug to approximately 12%.

In addition, the following cantons in Switzerland with a tax rate that already stands below 15% have stated they will, or are expected to, keep their low tax rates: Schwyz: 11.7 % (communities of Freienbach/Wollerau), Lucerne: 12.3% (11.3% in the lowest taxed community), Appenzell Ausserrhoden: 12.7%, Nidwalden: 12.7%, Obwalden: 12.7%, and Appenzell Innerrhoden: 14.3%.

As indicated above, the lowering of the headline tax rate is just one of several measures that are being contemplated to ensure the competitiveness and attractiveness of Switzerland for corporations once certain special tax regimes phase out in the 2018 to 2020 timeframe.

Jackie Hess (jahess@deloitte.ch)

Tel: +41 58 279 6312

Jacques Kistler (jkistler@deloitte.ch)

Tel: +41 58 279 8164

René Zulauf (rzulauf@deloitte.ch)

Tel: +41 58 279 6359

Deloitte