"Corporate tax reform III"

Switzerland's Corporate Tax Reform III aims to strengthen the tax competitiveness and attractiveness of Switzerland as a business location. An important component is the introduction of the so-called license box, which is specifically aimed at income from intellectual property rights (IP). License boxes enable reduced taxation of IP income, which encourages companies to retain existing rights and develop new ones. In Switzerland, the canton of Nidwalden was the first to introduce a license box solution in 2011. Liechtenstein followed with a similar regulation, which was confirmed by EFTA as compliant with EU law. These measures are aimed at preserving and creating high-quality jobs. The exact design of the license boxes varies greatly internationally, with Nidwalden having a rather restrictive application that makes it less attractive for companies. The future development of a Swiss license box will be influenced by consultations and negotiations with the EU and OECD.

Topics in the publication

• Corporate tax reform III
• License box solutions
• Economic considerations regarding the license box
• Legal conformity and international comparisons
• Comparison of tax burdens
• Income classes and scope of application
• Fictitious royalties
• Future of the license box in Switzerland