Federal practices for principal companies and Swiss Finance Branches from 1 January 2019

The STAF is a legislative measure to bring Swiss corporate tax law into line with international requirements. As announced in the Federal Council's message on tax proposal 17 (new: STAF), the regulations for principal companies and Swiss Finance Branches (federal practices) will also be abolished at practice level in this context.

Unlike the abolition of the regulations for cantonal status societies, the abolition of these federal practices does not require any legal adjustments.

From 1 January 2019 onwards, taxpayers will no longer be able to make use of the federal practices for tax separation for principal companies and the Swiss Finance Branches for the first time (so-called closure). Taxpayers who already use these practices prior to 1 January 2019 may also claim the practice in 2019. The same applies to taxpayers who will apply these federal practices for the first time as of 1 January 2019, based on a preliminary tax ruling, provided that the competent tax authority has countersigned the ruling prior to the publication of this practice announcement.

Circular No. 8 of the FTA on the international tax exemption of principal companies dated 18 December 2001 is amended accordingly.