According to a communication from the Federal Tax Administration dated 15 November 2018, the abolition of the privileged taxation regimes of principal companies and the Swiss Finance Branch is already imminent in view of the planned corporate tax reform. As of next year, these special forms of taxation, which are not based on an (explicit) legal basis, will no longer be available. The existing tax rulings for these taxation regimes will also be terminated soon once the status companies (« mixed companies ») are abolished by law.
Tax proposal 19, which is to be implemented instead of the failed Corporate Tax Reform III and expected to enter into force from 2020, will only provide for privileged taxation conditions for companies with income from intellectual property rights in line with international standards ("patent box").
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