PLEASE NOTE: THIS ARTICLE WAS ORIGINALLY SUBMITTED BY REVISUISSE PRICE WATERHOUSE, SWITZERLAND

The Federal Parliament passed a corporate tax reform which, in particular, shall improve the competitive position of Swiss holding companies. In addition the reform abolishes some uncertainties concerning the Cantonal tax treatment of Swiss special purpose companies, confirming the intention of the Federal Parliament to uphold the competitive position of Switzerland for entities operating internationally. The revised law shall enter into force as from January 1, 1998, provided that no referendum is initiated against the new provisions (which is unlikely to be the case).

The main highlights for foreign investors are:

Capital gains on the sale of substantial investments held by Swiss entities will basically be exempt from Federal income tax.

The annual Federal capital tax will be abolished.

A flat Federal income tax rate of 8.5% will be introduced

For Cantonal tax purposes a relief from income tax may be claimed by Swiss entities performing either administrative activities within Switzerland only, or performing its business activities mainly abroad.

The stamp duty rate will be reduced to 1%.

Corporate entities may hold their own shares, to the extent it is permissible in accordance with commercial law, for a period of up to 6 years without triggering a partial liquidation for tax purposes.

The content of this article is intended to provide a general guideline to the subject matter. Specialist advice should be sought about your specific circumstances.