Corporate tax reform is coming to Switzerland

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By Paulus Merks

Tax experts in Switzerland now predict that certain Swiss tax regimes — the cantonal tax regime, the holding regime and, in particular, the auxiliary company regime — will ultimately need to be repealed.

A repeal of these regimes will trigger the need for reform of Switzerland’s corporate tax system. Such a reform may include a redefinition of the tax base.

In particular, the auxiliary company regime, which offers a substantial exemption for foreign source income, has prompted disputes before the European Commission. Indeed, since 2007, the European Commission has taken the view that Swiss cantonal tax regimes, especially the so-called auxiliary company status, constitute prohibited state aid under the 1972 EU-Swiss Free Trade Agreement (FTA)…

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