Switzerland: Corporate Tax

The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.

Switzerland's shift to individual taxation by 2032 will fundamentally reshape the country's lump-sum taxation regime for internationally mobile individuals. The reform removes the requirement that both spouses must qualify simultaneously for lump-sum taxation, creating new planning opportunities for mixed-status couples while introducing complexities around asset allocation and minimum tax thresholds.

Find out how to become Swiss resident by moving to and working in Switzerland and the tax benefits available.

Senior executives within the meaning of Art. 15 para. 4 of the DTA Switzerland-Germany are specially taxed

OECD minimum tax (15%) has an impact on Switzerland's location advantages: Tax incentives such as the patent box or additional R&D deductions are losing much of their impact, as they would reduce the effective tax rate below 15% and thus trigger a top-up tax.

The establishment and operation of Alternative Investment Funds ("AIFs") (and their managers) is governed by the Federal Act on Collective Investment Schemes of 23 June 2006 ("CISA")...

Switzerland is a popular destination for non-Swiss nationals wishing to become Swiss resident.

Trusts have been around since the 12th century, starting in England and spreading to many legal systems worldwide, including those based on Common Law and Civil Law.

On 26 February 2024, Dixcart Trustee Switzerland (SA), became a regulated Swiss Trustee, as authorised by FINMA.