Tax submission 17 (12 April 2018)

1. social compensation in the AHV

Instead of an increase in family allowances, social compensation is to be provided via the AHV. The Commission has spoken out in favour of this core element of the proposal without opposition. It is based on the following basic idea: every franc of tax lost at federal, cantonal and municipal level as a result of tax bill 17 will be "counter-financed" with one franc of AHV funding.

In its message of 21 March 2018, the Federal Council estimates the static financial impact on the Confederation, the cantons and the municipalities (taking into account the cantonal implementation plans known to date) at CHF 1.78 billion. With the dividend taxation regulation proposed by the Commission (see point 2 below), this amount rises to CHF 2.1 billion. The fiscal effects of the adjustment to the capital contribution principle (see point 3 below) and the limited introduction of the deduction for self-financing (see point 4 below) are not yet clear due to the lack of detailed decisions, but should also be taken into account. Accordingly, the federal contribution to the AHV will be adjusted in the table below.

As a countermeasure, the AHV fund will be funded from the following three sources of financing with a total of CHF 2.1 billion.

2. partial taxation of dividends

The Commission proposes by 8 votes to 3 with 2 abstentions that dividends from qualified shareholders should be taxed at least 50% at cantonal level (Art. 7(1) and Art. 8(2quinquies StHG). A minority is in favour of the Federal Council's proposal (70%).

At the federal level, the commission joins the Federal Council without opposition (70%) (Art. 18b para. 1, 20 para. 1bis DBG).

3. adjustment to the capital contribution principle

The Commission is unanimously in favour of adapting the capital contribution principle by introducing a repayment regime (proportionality principle). In doing so, the Commission wants Switzerland to remain attractive for company settlements. Possible circumvention of the new regulations should be prevented. To this end, the WAK-S has requested further documentation from the FTA until the meeting on 24 May 2018.

4. deduction on self-financing

The Commission has decided, without opposition, not to allow the deduction on self-financing, except on an optional basis for high-tax cantons (Art. 25abis StHG). This instrument is not used at federal level. In addition, the deduction on self-financing will be integrated into the general limitation of relief (Art. 25b para. 1 of the Federal Tax Act).