With the reform of the Swiss corporate tax system, which came into force at the beginning of 2020, the former Swiss tax regimes which were criticised by the OECD and EU have been abolished and replaced by new, internationally compliant and competitive instruments. This was done with the aim of securing the tax attractiveness of Switzerland as a business location over the long term, ensuring international acceptance and guaranteeing sufficient tax revenues. You can see here how the requirements of the Federal Tax Harmonisation Act have been implemented in the cantonal tax laws.
Tax benefits for income from intellectual property rights are used to promote research and development and the resulting value creation in these areas. The wording of the law provides a precise definition of which patents or similar rights qualify for box taxation. In addition to this, the regulations contain detailed specifications on the calculation mechanism used as well as the documentation requirements. The nexus approach is consistent with the international OECD standard, and can be applied by patent, product or product families. The patent box deduction has been implemented in all cantons, but in some cases only to a limited extent.
Further information: www.patent-box.org
The introduction of an additional special deduction for research and development expenses is optional for the cantons, but in most cases has been introduced. This deduction may not exceed 50% of the relevant R&D expenses in Switzerland. It is left to the taxpayers to analyse to what extent they can benefit from the patent box, the special deduction or a combination of both.
Other changes include:
Tax Policy Switzerland, PwC Switzerland
Tel: +41 58 792 43 43