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"Tax proposal 17", consultation procedure: Which tax incentives are still available?

Posted by on 11 September 2017

The draft of the "Tax Proposal 17" has been released and incorporates most of the elements of the rejected corporate tax reform III, but as announced the notional interest deduction has been abandoned. The following blogpost summarises the main incentives of the Tax Proposal 17 and related measures. Especially with regard to the step-up options, the time has come to begin with tax planning.


We have prepared a pdf for you which gives you more insights about the following points:

I. Legislative development
II. The key elements of the new proposal

  1. Abolition of the privileged regimes
  2. Patent box
  3. Super-deduction for R&D
  4. Limitation of relief
  5. Significant decrease of cantonal profit taxes
  6. Step up for new tax payers in Switzerland
  7. Cantonal step–up possibility before the change of law
  8. Step-up with special tax rate
  9. Reduction of tax on equity
  10. Limitation of dividend relief
  11. Tightening of the so-called "Transposition"
  12. Increase of the share of the cantons of the direct federal tax
  13. Increase of the minimal family allowances

III. Conclusion

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Topics: Tax

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Dimitri M. Rotter

Dimitri joined our firm as an associate in 2003 and became a partner in 2013. Dimitri is a very experienced tax lawyer based at the Zug office but heads also the Geneva tax practice of the firm. He has a long standing practice of corporate tax due to his background with the Big Four accounting firms. He represents clients in tax litigation cases in the Swiss Courts up to the Supreme Court. Dimitri focuses on domestic and cross border tax, including tax optimisation, and selected aspects of VAT notably for private client and their investment structures where he assists clients with regard to all related legal aspects. Special domains of expertise are aviation tax and syndicated loans. He obtained his law degree from the University of Geneva (lic. iur.) in 1990 and was admitted to the Lucerne Bar in 1993. He qualified as a Swiss Certified Tax Expert in 2002. His working languages are German, French and English. Dimitri is a member of the Zug Bar Association, the Swiss Bar Association, the International Fiscal Association, EXPERTSuisse (Swiss Institute of Certified Accountants and Tax Counsels) and of the International Tax Planning Association (ITPA).

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