The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international developments in terms of corporate taxation.
The main features of TP17 are as follows:
- The cantons’ share of direct federal tax receipts will be increased from 17% to 21.2%, instead of 20.5%;
- Dividends from qualified participation should be taxed at 70% at federal level and at 70% at least at cantonal level. The relief restriction should be set at 70%;
- Companies will have to pay more tax and local SMEs less tax, despite the moderate increase in dividend taxation and the minimum requirements for family allowances;
- A mandatory patent box regime for all cantons, accompanied by additional deductions for research and development expenditure to be implemented on an optional basis;
- The overall tax relief of these measures would be limited to 70% to guarantee a minimum taxable profit of 30%.
If a referendum is not called, the first measures could come into force at the beginning of 2019 and most of them could come into force from 2020.
