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The implementation of the STAF in the cantons of Eastern Switzerland - selected topics of profit and capital taxation

Claude Aemisegger
Die Umsetzung der STAF in den Ostschweizer Kantonen – ausgewählte Themen der Gewinn- und Kapitalbesteuerung
in zsis)
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06 Cf. for example the compilation of the profit and capital tax burden - ordered by their respective amount in the individual cantons - for legal entities regarding the 2019 tax period in Pascal Hinny, Steuerrecht 2020, Textausgabe 2020, Zürich / Basel / Geneva 2020, p. 2369 (profit tax) and p. 2371 (capital tax), as well as the tax folders of the Federal Tax Administration regarding the simple approaches to profit and capital tax for legal entities, but without a "ranking list", available online at However, in some cantons of Eastern Switzerland, there is sometimes disagreement about their position in the nationwide "ranking list" of the cantons with the lowest profit tax rates. In February 2020, a corresponding controversy arose in the context of the vote in the canton of TG on the amendment of the law on state and municipal taxes (Tax Act), which dealt with the implementation of the STAF; in the message, the government made the statement that the canton of Thurgau would fall into the middle range in an intercantonal comparison of the first third of the cantons due to the planned reduction in the rate of profit tax (cf. the Message of the Cantonal Government of Thurgau on the referendum of 9 February 2020 on the Act of 11 September 2019 amending the Act on State and Communal Taxes [Tax Act], available online at On 4 February 2020, i.e. 5 days before the vote, the Canton of Thurgau's government council felt obliged to correct this statement in an official clarification; it stated that this statement was incorrect and that the Canton of Thurgau was already - before the implementation of the proposed profit tax reduction - in the middle range of the Swiss cantons in terms of profit tax and was therefore even worse placed than stated in the message, but noted that the Canton of Thurgau was in the middle range, i.e. in the middle of the Swiss cantons, with the proposed change.i.e. probably in 11th place, otherwise it would slip into the last third (see the corresponding clarification in the wording available online at It can be assumed that the authors of the message - as the clarification of 4 February 2020 indicates - presented the situation up to 2009, when the canton of Thurgau was actually in the first third of the Swiss cantons subject to profit tax.
08 Cf. message of the Government Council on the referendum of 9 February 2020, available online at, p. 10.

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