Ms Fabienne Limacher

Fabienne Limacher

Updates

Corporate Tax

Fundamental changes to Swiss withholding tax on interest payments
Switzerland | 09 August 2019

The Federal Council recently announced its intentions to resume the temporarily suspended Swiss withholding tax reform and set out the general framework to introduce a paying agent tax system with regard to interest payments. However, as the Federal Council's communication did not contain any details, it remains to be seen how the reform will be set out in the draft bill expected in Autumn 2019 and how it will affect paying agents and investors.

Welcome relaxation of Swiss withholding tax rules on foreign bonds guaranteed by Swiss parent company
Switzerland | 22 February 2019

The Swiss Federal Tax Administration recently relaxed its practice under which bonds that are issued by foreign resident issuers, but guaranteed by their Swiss resident parent company, are requalified as domestic issuances which trigger Swiss withholding tax on interest payments. The revised rules significantly increase the permissible use of proceeds in Switzerland.

Intra-group debt financing: updated safe haven rates and thin capitalisation rules
Switzerland | 15 February 2019

The Swiss Federal Tax Administration recently published the 2019 safe haven interest rates to be used on intra-group loans. Against this backdrop, this article provides an overview of the relevant Swiss tax rules associated with determining whether intra-group financing constitutes equity or debt for tax purposes and the consequences of each characterisation.