TP17 is a balanced compromise which is supported in particular by the cantons, as well as by the cities and communes. The dispatch is in line with the parameters set by the Federal Council on 31 January following intensive discussions with the key players. The aim is to introduce a mandatory patent box for all cantons and additional deductions for research and development expenditure on an optional basis. These measures will be accompanied by a relief restriction, which includes a binding provision for the cantons whereby at least 30% of companies' profits must always be taxed before these measures are applied.
The proposal also makes provision for dividends from qualified participations to be taxed at 70% by the Confederation and at least 70% in the cantons. Moreover, the Confederation's minimum guidelines for child and education allowances should be increased by CHF 30 per child.
In order to support the cantons in their plans to implement TP17, the cantons' share of direct federal tax receipts will be increased from 17% to 21.2%. The cantons will thus receive additional funds of around CHF 990 million per year. The cantons' tax revenue will increase by a further CHF 355 million as a result of the higher dividend taxation. The cantons are free to use these additional receipts for their implementation projects (e.g. profit tax reductions, patent box, deductions for research and development expenditure). The results of a survey on cantonal implementation plans are being published with the TP17 dispatch, thereby ensuring the greatest possible transparency with regard to the effects of the reform. Within the scope of the increase in the cantons' share of direct federal tax, the cantons are required to take the cities and communes into account too.
The starting point for the reform is the abolition of the arrangements for cantonal status companies which are no longer accepted internationally. TP17 and the cantonal implementation plans will ensure that Switzerland remains an attractive business location. Ultimately, TP17 will mean that status companies will have to pay more tax and local SMEs less tax, despite the moderate increase in dividend taxation and the minimum requirements for family allowances.
The reform will initially result in static receipt reductions, which should at least be offset in subsequent years by the dynamic effects expected. The dispatch sets out the possible trends for these dynamic effects.
At best, Parliament can adopt TP17 in the autumn session. If a referendum is not called, the first measures could come into force at the beginning of 2019 and most of them could come into force from 2020.
Botschaft zum Steuergesetz über die Steuervorlage 17(pdf, 1324kb)
Bundesgesetz über die Steuervorlage 17(pdf, 147kb)
Ergebnisbericht Vernehmlassungsverfahren zur Steuervorlage 17(pdf, 535kb)
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