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Related insights:

TAX Notional interest deduction on equity - Tax opportunities

2 min read | 07 Sep 2023

As of January 1, 2020, a notional income tax deduction for highly equity financed corpora-tions was introduced. Cantons with an effective profit tax burden of at least 18% are entitled to grant such notional interest deductions for cantonal taxes on certain qualifying equity. No deduction applies for direct federal tax. The reduction via application of the notional interest expense on equity capital is not granted on the entire equity, but on the security equity capital to be defined. The imputed interest rate is based on the yield for ten-year federal bonds, alt-hough a considerably higher third-party interest rate may also be applied for intra-group fi-nancing activities of the company.

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tax

Say goodbye to the arm’s length principle

24 Jul 2019

The G20 has endorsed the The Organisation for Economic Co-operation and Development’s (OECD’S) roadmap for resolving the ‘tax challenges arising from the digitalisation of the economy’. The reallocation of profits and minimum tax proposals [PDF 3 MB] that have emerged following a recent round of consultations could put an end to the arm’s length principle that has governed transfer pricing for decades.

After a slow and tentative start, the OECD’s push for a solution on how to allocate and tax the profits from digital business is gathering momentum.

Following consultations, initial proposals from earlier in the year have now been crystallised into a twin-pillar framework and a series of detailed options within it [PDF 3 MB]. With the backing of the G20, the OECD has also set an ambitious roadmap for reaching an internationally-agreed consensus by the end of 2020.

So, what is being proposed within the OECD’s programme of work and what are the implications?