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.
Amendment to the tax laws of the Cantons of Basel-Stadt and Basel-Landschaft - Tax Template 17 (SV17)
Prior to the revision of the cantonal tax law, the canton of Basel-Stadt was one of the cantons with the highest ordinary income tax rate, with an effective ordinary income tax burden of a maximum of 22.18%. Significantly lower tax rates, namely between 7.8% and around 11%, were applied to status companies. Despite this low tax rate, the share of the status companies in the canton's tax revenue from taxes on profits and capital amounted to 60%. When implementing the tax reform and AHV financing (STAF), the challenge for Basel-Stadt was therefore to reduce the ordinary profit tax rate to such an extent that the status companies do not migrate, but at the same time sufficient tax revenue can be generated. In addition, it was assumed - probably rightly so - that it was crucial to create legal certainty for the companies concerned as soon as possible, which is why the new tax rate was communicated very early on and the reduced tax rate came into force on 1 January 2019.
Compensation paid by Swiss companies to foreign directors
This video provides information on the possible tax and social security implications of a board of directors resident in an EU country in the case of a Swiss company limited by shares if the board of directors is also self-employed in its country of residence.
Withholding tax refund despite non-declaration in the tax return - National Council vote
Anyone who has not declared income in the tax return should still receive the withholding tax back if he has been negligent. The National Council has approved this change, but wants to go considerably further than the Federal Council.
Tax template 17 is linked to AHV restructuring
Tax Bill 17 will be linked to the AHV restructuring. This was decided by the Council of States. This approach is intended to help the corporate tax reform achieve a breakthrough and relieve the burden on old-age pensions.
Tax submission 17 (12 April 2018)
The Committee for Economic Affairs and Taxes of the Council of States (WAK-S) has already unanimously agreed to tax bill 17 at its meeting on 12 April 2018. At its meeting on 15 May 2018, the WAK-S unanimously supported an overall concept with the following four central elements:
Deductibility of fines and penalties
In its decision of 26 September 2016, the Federal Supreme Court had to rule on a case concerning the tax law admissibility of a provision in connection with an EU cartel fine. The affected X. AG filed an appeal against the decision of the Cantonal Tax Office of Zurich with the Tax Appeal Court of the Canton of Zurich, which upheld the appeal. The cantonal tax office appealed unsuccessfully against this decision to the Administrative Court of the Canton of Zurich, which dismissed the appeal in its ruling of 9 July 2014 on both state and municipal taxes and direct federal taxes. The cantonal tax office then lodged an appeal with the Federal Supreme Court in matters of public law.
ISIS) seminar folder "Corporate Tax Law (2025)"
All documents from the ISIS) seminar "Corporate Tax Law 2025" from June 02 + 03, 2025 under the direction of Peter Mäusli-Allenspach in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
Transfer pricing documentation - International and Switzerland (2025)
Workshop by Ivo Manatschal, Simona Studer and Thomas Hug on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Transfer pricing documentation - International and Switzerland"
