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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

Onshoring in Liechtenstein

16 Jun 2020

In the battle against profit shifting and base erosion, the Organisation for Economic Co-operation and Development (OECD) and the European Union (EU), as well as their member states, have continuously stepped up the pressure on zero- and low-tax countries by introducing what are known as grey and black lists. In particular, this has increased requirements in the fields of substance, anti-abuse provisions and exchange of information in tax matters.

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Onshoring in Liechtenstein

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