zsis) - Center for Swiss and International Tax Law

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

The eastern Swiss cantons of St. Gallen (SG), Thurgau (TG), Appenzell Ausserrhoden (AR) and Appenzell Innerrhoden (AI) have implemented a number of changes in the taxation of profits and capital as part of the STAF as of 1 January 2020. The present article examines individual voluntary measures and measures not harmonized in the STAF. The analysis focuses on the adjustments in profit tax rates and capital tax, past and future tax relief, the additional deduction for research and development expenses, and a selection of special practical features.

Implementation of the STAF in the Canton of Zurich

Although the Canton of Zurich dealt with the implementation of the Federal Law on Tax Reform and OASI Financing ("STAF") at an early stage and issued various practice notes, various implementation issues still arose in the months following its entry into force. This article deals with the current implementation practice of STAF in the Canton of Zurich, with a focus on the change of status and deductions for self-financing. The practical application of the patent box and the research and development deduction is still subject to announcements by the Zurich tax office.

Implementation of the STAF in the Canton of Ticino

On 1 January 2020, the Federal Act on Tax Reform and Financing of the OASI (STAF) (Riforma fiscale e finanziamento dell'AVS, RFFA) entered into force. Among other things, the federal law modified certain provisions of the Federal Direct Tax Act (DBG) and the Direct Tax Harmonisation Act (StHG). In doing so, the Confederation leaves the cantons some leeway in implementing the STAF in their own tax legislation. This article analyses the implementation of the STAF by the Canton of Ticino.

Implementation of the Federal Law on Tax Reform and OASI Financing (STAF) in the Canton of Berne

Based on the Corporate Tax Reform Act III (USR III) passed by the Federal Parliament on 17 June 2016, the Berne Cantonal Government Council expressed its views on the content of USR III at the end of November 2016, as well as the possible effects on the Canton of Berne and the preliminary positioning of the Canton of Berne in intercantonal tax competition. In the interests of Berne as a business location, the Government Council intended to cushion the abolition of cantonal tax privileges and the associated transition to ordinary taxation with replacement measures as part of the revision of the tax law in 2019. It was planned to reduce the maximum tax burden on profits from 21.64% in two steps; namely to 20.20% in 2019 and then to 18.71% in 2020. Further reductions in the profit tax rate should then have taken place with the 2021 tax law revision. In addition, the 2019 tax law revision also provided for the reduction of the applicable capital tax rate.