Tax Alert Switzerland April 2017

Switzerland: An attractive location to onshore corporate mobile income functions

International hybrid tax structures are being challenged. Preferred mobile income jurisdictions including Switzerland are in the spotlight of discussion. Switzerland welcomes changes and has taken actions to further develop its corporate tax law framework to maintain and improve its attractiveness for international business.

A modified Swiss corporate tax reform, after the February 2017 rejection of what has been seen to be a too business friendly tax reform, is being addressed. In particular, the tax treatment of corporate mobile income functions will be streamlined. The coming rules are expected to become effective around 2020-2022, until when the existing tax incentives will be in force including transition clauses.