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SWITZERLAND: Corporate Tax Reform III

On 22 September 2014, the Swiss Federal Government published draft legislation for the IIIrd Corporate Tax Reform ('CTR III') and invited interested parties to submit comments until 31 January 2015.

The proposed tax reform package replace the existing cantonal preferential tax regimes for holding, administrative, domiciliary and 'mixed' companies within a certain period (extension of the existing practise might be extend for 10 years) with a tax-free basis step-up of assets that previously benefited of the abolished preferential regimes and introduces a new license box regime at the cantonal and communal level, as well as a notional interest deduction regime at all taxation levels.

Furthermore several cantons plan a reduction of the corporate tax and on a federal level the capital stamp duty should be abolished, a reform of the participation deduction system and an introduction of new rules on the realization of hidden reserves and on tax loss carryover are planned.

The reform plans also includes tax measures affecting individuals, negatively by an introduction of capital gains taxation on securities held by private individuals and positively by changes to the taxation of dividends received.

According to the propose time schedule the final new law should enter into effect in 2017 or 2018 at the earliest, depending on whether a vote will take place.

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