Editorial

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

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

Editorial

Using the tax system to attract investment into a country is nothing new. The UK has come under pressure over the lengths to which it is going to ensure potential foreign investors see it as "open for business", with the Patent Box regime coming under challenge and with claims the country is becoming a tax haven through its attractive controlled foreign company (CFC) rules and declining corporate tax rate. But if one country has been a trailblazer in this regard, it is Switzerland.

Switzerland was having its tax policies challenged by the EU when the UK's Patent Box regime was merely a twinkle in its implementers' eyes. Now, against a backdrop of international reforms and unprecedented levels of transparency and scrutiny of multinational tax affairs, in tandem with pan-European harmonisation measures, the scope for challenge of national regimes is increasing. Examples such as the US Foreign Account Tax Compliance Act, and the way in which it has been imposed on financial institutions and tax authorities around the world, highlight that outliers will no longer be tolerated.

With this in mind, Schellenberg Wittmer looks at what the international debate on tax transparency means for Swiss levels of information exchange.

Deloitte narrows that line of enquiry to focus on tax transparency trends in global banking and analyse how these patterns are likely to impact the Swiss financial services sector. Staying with FS, burckhardt explains the taxation of option rights granted to shareholders.

PwC tackles domestic reform, and looks in detail at specific measures including the proposed Licence Box for innovation and the notional interest deduction on surplus equity.

KPMG assesses the Swiss mobility challenge. Immigration changes are making it harder to enter the country while companies are having trouble convincing employees to leave the attractive working environment behind.

Distracted by attractive direct tax rules, potential investors in Switzerland often overlook indirct tax concerns. But here KPMG outlines advantages in the Swiss VAT system. The firm also identifies what impact OECD-level discussions on base erosion and profit shifting will have on the country, and provides a primer on taxpayer priorities when making acquisitions in Switzerland.

Many of these – mobility challenges, BEPS issues, increasing exchange of information – could be perceived as a threat to the position Switzerland holds within the international tax and finance framework, and that is precisely what Tax Partner – Taxand tackles in an article looking at the decisions that will be necessary to maintain competitiveness and attractiveness

Matthew Gilleard

Corporate Tax editor

International Tax Review

more across site & bottom lb ros

More from across our site

ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
Chinwe Odimba-Chapman was announced as Michael Bates’ successor; in other news, a report has found a high level of BEPS compliance among OECD jurisdictions
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
The rules are intended to implement the substance of an earlier OECD report in its entirety
While new technology won’t replace the human touch, it could help relieve companies’ staffing issues, EY’s David Helmer and Daren Campbell tell ITR
The firm said the financial growth came from increased demand for its AI services and global tax reform advice
Chrystia Freeland had also been the figurehead of Canada’s controversial digital services tax adoption, which stoked economic tensions with the US
Panama has no official position on pillar two so far and a move to implement in Costa Rica will face rejection, experts tell ITR
The KPMG partner tells ITR about Sri Lanka’s complex and evolving tax landscape, setting legal precedents through client work, and his vision for the future of tax
Overall turnover at the firm also reached a record £8 billion; in other news, Ashurst and Dentons announced senior tax partner hires
Gift this article