Taxation

OECD/G20 Project on the Taxation of the Digitalized Economy
The OECD/G20 project on taxation of the digital economy comprises profit redistribution (Pillar 1) and the introduction of a global minimum tax of 15% for large corporations (Pillar 2). While Pillar 1 is blocked, Pillar 2 has already been implemented by various countries. However, the US under President Trump is now likely to succeed in implementing a special solution with the side-by-side system, which largely exempts US corporations from IIR and UTPR. The side-by-side system is to be adopted by the end of 2025, which will give the US a clear competitive advantage. The OECD is currently working on Administrative Guidance to implement this. However, negotiations are stalling: emerging economies fear disadvantages and companies criticize the excessive complexity. Due to these developments, Switzerland needs to find other ways to increase the attractiveness of the location.
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Extension of Loss Carry-Forwards
The federal law on extending loss carry-forwards extends the period for loss carry-forwards from seven to ten years. The regulation is to apply retroactively from the 2020 tax year. The aim is to strengthen economic resilience and give companies more flexibility after crises. The National Council has approved the bill. The matter is on the agenda for the EATC-S meeting in November. SwissHoldings expressly supports the extension. In view of increasing uncertainties, a seven-year carryforward period is no longer appropriate.
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Improving investment conditions for companies
Motions 25.4192 and 25.4264 call on the Federal Council to examine measures to strengthen investment activity and competitiveness in Switzerland. In particular, excess depreciation and tax credits for large investments should be considered in order to reduce investment costs. The motions are likely to be on the agenda for the winter session. SwissHoldings expressly supports these approaches. The proposed measures specifically promote investment in research, development, and high-quality production activities without creating inefficient subsidies. Both instruments strengthen Switzerland's attractiveness as a business location and secure long-term jobs and tax revenues in Switzerland.
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Strengthening Switzerland as a location for production and research
Two new motions (25.4191 and 25.4265) call on the Federal Council to examine new incentives to strengthen research, development, and production in Switzerland. In particular, additional tax deductions for production costs and new tax credits for research and development activities should be considered. The motions are expected to be on the agenda for the winter session. SwissHoldings expressly welcomes this. In order for Switzerland to maintain and further expand its prosperity, decisions must now be made on how Switzerland should reposition itself and which instruments will lead it to a successful future. In doing so, particular focus should be placed on new approaches.
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International Tax Law

National Tax Law

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Recent

Editorials

OECD Minimum Tax: How Donald Trump Is Rewriting the Global Tax Architecture – and How Europe Can Respond

The United States under President Trump is taking a step back from the consensus on the OECD minimum tax and is pursuing its own rules....

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Editorials

Underrated, but indispensable for international business: Double Taxation Agreements

Switzerland has currently signed double taxation agreements with over 100 countries. This network is constantly being renewed and expanded....

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Press releases

Tax Talks 2024: The minimum tax changes the competition between locations in the long term – what does this mean for Switzerland?

The OECD minimum taxation should ensure that multinational companies pay at least 15% tax on their profits. In Europe, implementation is...

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International Tax Law

Federal Council decides to introduce the OECD minimum tax in 2024

SwissHoldings notes with great concern the Federal Council’s decision to introduce the OECD minimum tax in 2024. The decision is not...

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Statements & Positions

Statement on the consultation draft of a federal law on the taxation of mobile work in international context

SwissHoldings has commented on the consultation draft on the taxation of mobile working (“home office”). This statement was...

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Statements & Positions

Comment Letter on Swiss OECD Minimum Taxation Ordinance

SwissHoldings comments on the Federal Council’s draft ordinance published on May 24, 2023 on the minimum taxation of large corporate...

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Contact

Martin Hess

Head Tax Policy, Member of the Executive Committee

+41 31 356 68 61
martin.hess@swissholdings.ch

Claudiu Antal

Deputy Head Tax Policy

+41 31 356 68 69
claudiu.antal@swissholdings.ch

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