Clarity on Swiss Taxes 2019
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Clarity on Swiss Taxes Playing to natural strengths 4 16 Corporate taxation Individual taxation Clarity on Swiss Taxes EDITORIAL Welcome Switzerland remains competitive on the global tax stage according to KPMG’s “Swiss Tax Report 2019”. This annual study analyzes corporate and individual tax rates in Switzerland and internationally, analyzing data to draw comparisons between locations. After a long and drawn-out reform process, the Swiss Federal Act on Tax Reform and AHV Financing (TRAF) is reaching the final stages of maturity. Some cantons have already responded by adjusting their corporate tax rates, and others are sure to follow in 2019 and 2020. These steps towards lower tax rates confirm that the Swiss cantons are committed to competitive taxation. This will be welcomed by companies as they seek stability amid the turbulence of global protectionist trends, like tariffs, Brexit and digital service tax. It’s not just in Switzerland that tax laws are being revised. The national reforms of recent years are part of a global shift towards international harmonization but also increased legislation. For tax departments, these regulatory developments mean increased pressure. Their challenge is to safeguard compliance, while also managing the risk of double or over-taxation. In our fast-paced world, data-driven technology and digital enablers will play an increasingly important role in achieving these aims. Peter Uebelhart Head of Tax & Legal, KPMG Switzerland Going forward, it’s important that Switzerland continues to play to its natural strengths to remain an attractive business location and global trading partner. That means creating certainty by finalizing the corporate tax reform, building further on its network of FTAs, delivering its “open for business” message and pressing ahead with the Digital Switzerland strategy. Our multidisciplinary teams closely follow shifts in the international and Swiss tax landscape, seek innovative ways to respond to change, and deliver expert advice – whatever your current tax topic. Individual taxation Peter Uebelhart 3 SWISS TAX REPORT 2019 Corporate taxation Corporate income tax Attractive tax rates remain a natural strength in Switzerland. With some cantons already preparing for the changes that Switzerland’s new tax law will bring, the cluster of lower tax cantons in central and eastern Switzerland is less striking due to lower rates overall. Switzerland compares favorably to most of Europe and is likely to retain this position even as countries like the UK and France successively lower their rates. 4 Clarity on Swiss Taxes 5 CORPORATE TAXATION: CORPORATE INCOME TAX Which businesses are shouldering the tax burden in Switzerland? While over two-thirds of taxable companies pay virtually no tax, 2.80% carry around 90% of the total direct (federal) tax burden. This means the tax burden is shouldered by an even smaller number of companies than in the prior year (2018: 2.93%). Contribution of businesses to tax revenues from direct federal taxes 88.08% (by profit levels) 67.43% Taxpayers 13.47% 10.77% Contribution to 9.43% direct federal 2.80% taxes 1.08% 5.53% 1.24% 0.16% Taxable profit in 0 - 10 10 - 50 50 - 100 100 - 1000 1000+ CHF 1,000/year Note: Latest available data for the tax period 2015. Source: Swiss Federal Tax Administration FTA, 2019, https://www.estv.admin.ch/estv/de/home/allgemein/ steuerstatistiken/fachinformationen/steuerstatistiken/direkte-bundessteuer/dbst-jp-kantone-2015.html. 6 Clarity on Swiss Taxes Corporate income tax rates in the cantons – 2018 and 2019 The cantons of central Switzerland continue to dominate in terms of lowest ordinary corporate income tax rates. Tax rates in these cantons were generally stable, with very modest downward adjustments in Zug, Schwyz and Glarus only, and a negligible increase in Schaffhausen. Basel-Stadt and Vaud stand out for their drastic tax cut rates (from 22.18% to 13.04% and 21.37% to 14.00%, respectively) in anticipation of the changes to come from TRAF. Further cuts are expected in higher tax cantons, including Geneva, Bern and Zurich, also in connection with TRAF. 12.32 2018 Lucerne 12.32 2019 12.66 Nidwalden 12.66 Figures in percent 12.74 Obwalden 12.74 Appenzell A. 13.04 13.04 22.18 Basel-Stadt 13.04 Vaud 21.37 14.00 14.16 Appenzell I. 14.16 14.51 Zug 14.35 14.92 Uri 14.92 Schwyz 15.19 15.02 15.61 Neuchâtel 15.61 15.70 Glarus 15.68 15.75 Schaffhausen 15.82 16.12 Grisons 16.12 Thurgau 16.43 16.43 17.40 St. Gallen 17.40 18.61 Aargau 18.61 19.86 Fribourg 19.86 20.53 Jura 20.53 20.55 Ticino 20.55 Basel-Landschaft 20.70 20.70 21.15 Zurich 21.15 Solothurn 21.38 21.38 21.64 Bern 21.63 21.74 Valais 21.74 24.16 Geneva 24.16 Note: max. effective rate on pre-tax profits for federal/cantonal/municipal taxes in the respective cantonal capital. Corporate income tax figures for AI, GL, NE, GE, JU and SG for 2018. The income tax rate of Schaffhausen is based on the tax rate before the vote on 24 March 2019. Source: KPMG Switzerland. 7 CORPORATE TAXATION: CORPORATE INCOME TAX Corporate income tax rates in the cantons – trend 2007 to 2019 Ordinary corporate income tax rates barely changed in the Mittelland, Western Switzerland and city cantons. Only Bern, Uri and Ticino cut rates more extensively. Corporate income tax rates fell particularly sharply in Neuchâtel, Schaffhausen, Grisons, Basel-Stadt and Vaud. It is interesting to note that 12% has become established as the minimum rate in practice. 21.57 2007 Valais + 0.17 21.74 2019 24.24 Geneva - 0.08 24.16 Figures in percent 21.32 Zurich - 0.17 21.15 13.12 Obwalden - 0.38 12.74 16.98 Thurgau - 0.55 16.43 21.12 Jura - 0.59 20.53 15.47 Appenzell I. - 1.31 14.16 22.76 Solothurn -1.38 21.38 16.32 Uri - 1.40 14.92 22.00 Ticino - 1.45 20.55 19.08 St. Gallen - 1.68 17.40 16.10 Zug - 1.75 14.35 23.40 Bern -1.77 21.63 21.95 Fribourg - 2.09 19.86 22.32 Aargau - 3.71 18.61 19.98 Glarus - 4.30 15.68 17.27 Nidwalden - 4.61 12.66 19.76 Schwyz - 4.74 15.02 25.65 Basel-Landschaft - 4.95 20.70 18.04 Appenzell A. - 5.00 13.04 22.18 Neuchâtel - 6.57 15.61 18.90 Lucerne - 6.58 12.32 22.84 - 7.02 Schaffhausen 15.82 23.53 - 9.53 Vaud 14.00 24.81 - 11.77 Basel-Stadt 13.04 29.06 Grisons - 12.94 16.12 Note: max. effective rate on pre-tax profits for federal/cantonal/municipal taxes in the respective cantonal capital. Corporate income tax figures for AI, GE, GL, JU, NE and SG for 2018. Source: KPMG Switzerland. 8 Clarity on Swiss Taxes Corporate income tax rates in the cantons – trend 2007 to 2019 The recent dip in average Swiss tax rate is attributable primarily to the cuts in Basel-Stadt and Vaud. The trend is set to continue with a larger fall in 2020 when new legislation (TRAF) is expected to come into force. 20.76% – 3.70% 19.44% 18.96% 18.70% 18.31% 18.06% 18.01% 17.90% 17.89% 17.80% 1 7. 7 4 % 17.71% 17.06% 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Note: max. effective rate on pre-tax profits for federal/cantonal/municipal taxes in the respective cantonal capital. Corporate income tax figures for AI, GE, GL, JU, NE and SG for 2018. Source: KPMG Switzerland. Corporate income tax rates in the cantons – trend 2007 to 2019 The trend towards stagnation of corporate tax rates continues in 2019. Only Basel-Stadt and Vaud reduced their corporate tax rates. LLucerneuzern 28% NNidwaldenidwalden OObwaldenbwalden AAppenzellppenzell A A..(AR) AAppenzellppenzell I .I.(AI) 24% ZZugug UUriri SSchwyzchwyz NNeuchâteleuenburg 20% GGlaruslarus SSchaffhausenchaffhausen GGrisonsraubünden TThurgauhurgau 16% SSt.t. G Gallenallen AAargauargau FFribourgreiburg JJuraura 12% TTicinoessin BBasel-Landschaftasel-Landschaft ZZurichürich WVaudaadt 8% 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Note: max. effective rate on pre-tax profits for federal/cantonal/municipal taxes in the respective cantonal capital. Corporate income tax figures for AI, GE, GL, JU, NE and SG for 2018. Source: KPMG Switzerland. 9 CORPORATE TAXATION: CORPORATE INCOME TAX Corporate income tax rates in the cantons 2019 10 Clarity on Swiss Taxes Cantons with a corporate income tax rate above the Swiss average (17.06%) Cantons with a corporate income tax rate below the Swiss average (17.06%) Figures in percent 15.8 13.0 Schaffhausen Basel-Stadt 16.4 Thurgau 18.6 Aargau 13.0 20.7 21.2 Appenzell A. 20.5 Basel-Landschaft Zurich Jura 14.2 Appenzell I. 21.4 Solothurn 14.4 Zug 1 7. 4 12.3 St. Gallen Lucerne 15.0 15.6 Schwyz Neuchâtel 15.7 12.7 Glarus Nidwalden 12.7 21.6 Obwalden Bern 14.9 Uri 16.1 19.9 Grisons 14.0 Fribourg Vaud 20.6 Ticino 21.7 Valais 24.2 Geneva 11 CORPORATE TAXATION: CORPORATE INCOME TAX The cantons compared with European countries The comparison with Europe shows hardly any change in lower tax rates, with the cantons of central Switzerland enjoying a particularly positive position. They are joined now by Basel-Stadt and Vaud. The Channel Islands and certain (south) eastern European states are the only locations to offer even lower ordinary corporate income tax rates.