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Switzerland<br />

2.3 Tax <strong>policy</strong> <strong>outlook</strong> <strong>for</strong> <strong>2015</strong> — summary<br />

Corporate income <strong>tax</strong> burden<br />

Lower No change Higher<br />

Personal income <strong>tax</strong> burden<br />

VAT/GST/sales <strong>tax</strong> burden<br />

X<br />

X<br />

Lower No change Higher<br />

X<br />

Lower No change Higher<br />

2.4 Tax <strong>policy</strong> <strong>outlook</strong> <strong>for</strong> <strong>2015</strong> — detail<br />

Corporate income <strong>tax</strong>es<br />

• As a result of international developments, Swiss policies on<br />

the granting of <strong>tax</strong> privileges in the cantons are under review.<br />

Plans are to abolish the status of “domicile company,” to<br />

adjust the cantonal holding privilege to meet international<br />

standards and to introduce a minimum <strong>tax</strong> rate <strong>for</strong> holding<br />

and mixed companies. In addition, <strong>for</strong>eign and domestic<br />

income generated by mixed companies is to be treated<br />

equally <strong>for</strong> <strong>tax</strong> purposes in order to satisfy EU calls <strong>for</strong> an end<br />

to what is known as “ring-fencing.”<br />

• In return, royalties should be <strong>tax</strong>ed at a reduced rate at the<br />

cantonal level by means of a royalty box, and an interest-<br />

<br />

capital has been proposed. Adjustments are also to be<br />

made to cantonal <strong>tax</strong>es on capital. Further measures under<br />

discussion are the abolition of the issue <strong>tax</strong> on equity capital,<br />

adjustments to participation deductions and the offsetting of<br />

losses.<br />

• The average cantonal corporate income <strong>tax</strong> rates could be<br />

lowered from 22% (currently) to around 14%.<br />

• <br />

consultation on this proposal ends on 31 January <strong>2015</strong>. Any<br />

law changes will not be enacted be<strong>for</strong>e 2017.<br />

Taxes on wages and employment<br />

• Restrictions of lump-sum <strong>tax</strong>ation of wealthy <strong>for</strong>eigners will<br />

be enacted as of 2016 as a result of this <strong>tax</strong> model being<br />

perceived as somewhat unfair. In that regard, the model has<br />

come under international pressure. That said, an initiative to<br />

completely abolish lump-sum <strong>tax</strong>ation was dismissed by the<br />

Swiss people in 2014.<br />

Inheritance <strong>tax</strong><br />

• The Swiss Socialist Party successfully launched an initiative<br />

<br />

general exemption threshold of CHF2 million <strong>for</strong> inheritance<br />

and an exemption threshold of CHF20,000 per annum<br />

<strong>for</strong> occasional gifts and donations. Spouses or registered<br />

partners shall be exempt from the <strong>tax</strong>.<br />

• A popular vote on this initiative will take place in <strong>2015</strong>.<br />

Today, there is no inheritance or gift <strong>tax</strong> at the federal level.<br />

VAT, GST and sales <strong>tax</strong>es<br />

• A re<strong>for</strong>m of the Swiss VAT system was launched in 2014 and<br />

could enter into <strong>for</strong>ce as early as January 2016. Most of the<br />

proposed changes are of a technical nature. However, as a<br />

consequence of the proposed broadening of the <strong>tax</strong> base,<br />

more <strong>for</strong>eign businesses will have to register <strong>for</strong> Swiss VAT if<br />

th<strong>ey</strong> do business in Switzerland.<br />

176 | The <strong>outlook</strong> <strong>for</strong> <strong>global</strong> <strong>tax</strong> <strong>policy</strong> in <strong>2015</strong>

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