DOCSLIB.ORG

Corporate Taxation System in Switzerland

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Corporate Taxation System in Switzerland BLUM Attorneys at Law CORPORATE TAXATION SYSTEM IN SWITZERLAND Outline of Swiss Corporate Tax System Levels of Taxation in Switzerland Resident companies are subject to: • federal corporate income tax, and • cantonal/communal corporate income taxes, and • cantonal/communal capital taxes. Resident / Non-Resident Companies Corporate taxpayers are resident under Swiss domestic tax laws if either their corporate seat or place of effective management is located in Switzerland. Resident companies are subject to world- wide taxation, excluding income allocable to foreign permanent establishments and income from foreign real estate. Non-resident companies may be subject to Swiss corporate tax if they: • are partners in a Swiss partnership; or • have a permanent establishment in Switzerland; or • own Swiss real estate; or • have claims secured by a mortgage on Swiss real estate; or • deal with Swiss real estate respectively act as a broker thereof. Non-resident companies are taxed only with respect to their Swiss income and Swiss assets. The income attributable to a Swiss permanent establishment of a foreign corporation is determined under the direct method, i.e. based on the books of accounting of said permanent establishment. Corporate Income Taxes Corporate income taxes are levied both at the federal and the cantonal/communal level. The federal corporate income tax is levied at the rate of 8.5%. Given that taxes themselves are treated as a tax deductible expense for purposes of determining the company's taxable income, the effective rate of federal corporate income tax amounts to 7.83%. Cantonal corporate income tax rates vary consid- erably from canton to canton. On average, they are around 13%. In the fiscal year 2007, the canton of Obwalden is the most favorable canton with a combined corporate income tax rate for the canton and the communes of 6.6% and an effective rate of 5.62%. Capital Taxes The cantonal/communal capital tax is levied annually on the fully paid-in share capital and the re- serves (net equity) of a resident company or branch as of the end of the fiscal year. The tax rates vary from canton to canton; on average they are around 0.4%. Reduced tax rates apply to tax privi- leged companies. In the fiscal year 2007 the cantonal/communal capital tax rate in the canton of Obwalden amounts to 0.2%. Participation Exemption Swiss corporations and Swiss branches holding a qualified participation (at least 20% of the stock of another corporation, whether Swiss or foreign, or representing a fair market value of at least CHF 2 million) are granted a dividend received deduction both at the federal and cantonal/communal level. Accordingly, the corporate income tax is reduced in the proportion which the net dividend income from such participations bears to the total net taxable income. As a result, such dividend income is virtually exempt from tax. 500684/000226.doc Capital Gains Capital gains realized upon the disposition of a qualified participation also qualify for the dividend received deduction both at the federal and cantonal/communal level, provided such participation has been held for at least one year. Holding Privilege In addition, all cantons grant a holding company privilege to pure holding companies which results in full tax exemption at the cantonal/communal level also for income other than dividends from qualifying participations. Generally, the requirements for the holding company privilege are: • the articles of incorporation state that the company’s exclusive or main purpose is the hold- ing of participations (i.e. no active business activity); and • either 2/3 of the total assets consist of qualifying participations; or • 2/3 of the total income is derived from qualifying participations. Consequently, pure holding companies only pay federal corporate tax on the income that does not qualify for the federal dividend received deduction. Domiciliary Companies All cantons provide for a privileged tax regime for domiciliary companies. A resident company quali- fies as a domiciliary company if its activities are predominantly performed abroad and the activities performed in Switzerland are of an administrative nature only (e.g. headquarters of multinational enterprises). The privileged tax regime for domiciliary companies is only available at the can- tonal/communal level, but not at the federal level. Qualifying income from participations is tax-free. Only a small portion of foreign source income (up to 15%), which is determined in accordance with the importance of the administrative activities performed in Switzerland, is included in the company’s tax base. The tax base so determined is subject to cantonal/communal corporate income tax at the ordinary tax rates. On the other hand, Swiss source income is fully included in the company’s tax base. Business expenditures are de- ductible from the income to which they have a business correlation. Reduced capital tax rates apply to domiciliary companies. Auxiliary/Mixed Companies Auxiliary companies (also called mixed companies) are permitted to perform limited business activi- ties in Switzerland. As a general rule, at least 80% of the total income must emanate from foreign sources. Hence, Swiss source income may not exceed 20% of the company’s total income. Addi- tionally, 80% of the expenses must be related to the business activities performed abroad. The tax regime applicable to auxiliary companies is the same as the domiciliary company tax regime, with the exception that the portion of foreign source income to be included in the tax base is determined in accordance with the importance of the business activities performed in Switzerland. Tax Losses For federal and cantonal/communal tax purposes, losses may be carried forward for seven years but cannot be carried back. Thin Capitalization Rules Under the federal thin capitalization guidelines, an asset base test is used to determine whether a company is adequately financed. For each type of asset, only a specific percentage may be fi- nanced with debt from related parties. Interest expense on related party debt in excess of the maximum debt-to-equity ratio is not deductible for federal corporate tax purposes. Only a few cantons have explicit provisions on minimum equity requirements. Many cantons apply the federal thin capitalization guidelines described above. In other cantons a debt-to-equity ratio of 6:1 may be used. Transfer Pricing Switzerland has no statutory transfer pricing rules. The Swiss tax authorities accept and apply the transfer pricing methods promulgated by the OECD. Hence, transactions between affiliated compa- nies must observe the principle of dealing at arm's length. 000226.doc 2/5 Issuance Stamp Tax At the federal level a 1% issuance stamp tax is levied on the issuance as well as the increase of participation rights, against consideration or gratuitously, with the amount of CHF 1,000,000.00 remaining exempt from tax. The establishment of a Swiss branch, however, does not trigger the issuance stamp tax. Transfer Stamp Tax At the federal level a transfer stamp tax is levied on the transfer of title to taxable securities for consideration, if at least one of the parties to the transaction or an intermediary involved in the transaction qualifies as a domestic securities dealer. Federal Withholding Tax The federal withholding tax is levied at the rate of 35% on the distribution of profits (including con- structive dividends) and liquidation proceeds by a Swiss joint stock-company. A distribution is any payment by the company to its shareholder other than a repayment of stated capital. Profits distrib- uted by a Swiss branch to its foreign head office are not subject to withholding tax No withholding tax is levied on royalties. As from July 1, 2005 the Savings Tax Agreement between Switzerland and the EU has been in force, which has introduced measures equivalent to those laid down in the EU Parent-Subsidiary Directive and the EU Interest & Royalty Directive, namely the abolition of withholding tax on cross- border payments of dividends and on cross-border interest and royalty payments between associ- ated companies. Value Added Tax The standard VAT rate is 7.6%. The tax base is, generally, the consideration received from the contracting party. Taxable Year For each fiscal period only one tax return, which serves for federal, cantonal and communal taxes, must be filed. Ruling Practice Binding rulings may be obtained from the Swiss tax authorities within a few weeks. Treaty Withholding Tax Rates at a Glance For treaty countries, the rates below reflect the withholding tax rates applicable to outbound pay- ments. A zero rate applies to royalties. Countries Dividends % Interest % Albania 5/15 (N1) 5 Algeria (N2) 5/15 (N3) 10 Argentina (N4) 10/15 (N1) 12 Armenia (N2) 5/15 (N1) 10 Azerbaijan (N11) 5/15 (N3) 10 Australia 15 10 Austria 0/15 (N3) 0 Belarus 5/15 (N1) 8 Belgium 10/15 (N1) 10 Bulgaria 5/15 (N1) 10 Canada 5/15 (N5) 10 China 10 10 Croatia 5/15 (N1) 5 Czech Republic 5/15 (N1) 0 Denmark 0 0 Ecuador 15 10 000226.doc 3/5 Egypt 5/15 (N1) 15 Estonia 5/15 (N3) 10 Finland 0/10 (N3) 0 France 0/15 (N6) 0 Germany 0/15 (N3) 0 Greece 35 10 Hungary 10 0 Iceland 5/15 (N1, N7) // 15/10 (N8) 0 India 10 10 Indonesia 10/15 (N1) 10 Iran 5/15 (N9) 10 Ireland 0 0 Israel 5/15 (N6) 10 Italy 15 12.5 Ivory Coast 15 15 Jamaica 10/15 (N6) 10 Japan 10/15 (N1) 10 Kazakhstan 5/15 (N6) 10 Kirgizstan 5/15 (N1) 5 Kuwait 15 10 Latvia 5/15 (N3) 10 Liechtenstein - 0 (N10) Lithuania 5/15 (N3) 10 Luxemburg 0/15 (N1) 10 Macedonia
Load more

Recommended publications
  • Sweden Country Highlights
    International Tax Sweden Highlights In Plain English 1701 Pennsylvania Ave NW, Suite 200 Washington, DC. 20006, USA Phone : +1 202 792 6600 www.CastroAndCo.com Investment basics: Surtax – There is no surtax. Currency – Swedish Krona (SEK) Alternative minimum tax – There is no alternative minimum tax. Foreign exchange control – No Taxation of dividends – Dividends received Accounting principles/financial statements by a Swedish resident company from – Principles applied are in accordance another Swedish company normally are with the Annual Accounts Act, the Swedish exempt from tax, provided the shareholding Accounting Standards Board, the Swedish is business-related. Dividends received Financial Accounting Standards Council and from a nonresident company also may be the Swedish Institute of Authorized Public exempt if the shareholding is business- Accountants. related (see under “Participation exemption,” below). Even if qualifying for the exemption, Principal business entities – These are the dividends will not be exempt if the dividend private/public limited liability company (AB), payment is treated as a tax-deductible partnership (KB and HB), sole proprietorship, expense in the country of the payer and branch of a foreign company. company. Other dividends are included in Corporate taxation: business income and taxed at the corporate tax rate applicable for the financial year. Residence – A corporation is resident in Sweden if it is incorporated in accordance Capital gains – Capital gains derived from with the Companies Act. the sale
    [Show full text]
  • Overview of the SWISS TAX SYSTEM
    OVERVIEW OF THE SWISS TAX SYSTEM 10.1 Taxation of Corporate Taxpayers ...................................... 109 10.2 Tax Rate in an International Comparison ........................ 112 10 10.3 Taxation of Individual Taxpayers ..................................... 113 10.4 Withholding Tax ................................................................ 116 10.5 Value Added Tax................................................................ 117 10.6 Other Taxes........................................................................ 120 10.7 Double Tax Treaties .......................................................... 121 10.8 Corporate Tax Reform III .................................................. 121 10.9 Transfer Pricing Rules....................................................... 121 Image Tax return, stock image The Swiss tax system mirrors Switzerland’s federal struc- 10.1 TAXATION OF CORPORATE TAXPAYERS ture, which consists of 26 sovereign cantons with 2,352 10.1.1 Corporate Income Tax – Federal Level independent municipalities. Based on the constitution, all The Swiss federal government levies corporate income tax at a flat rate of 8.5% on profit after tax of corporations and cooperatives. cantons have full right of taxation except for those taxes For associations, foundations, and other legal entities as well as that are exclusively reserved for the federal government. As investment trusts, a flat rate of 4.25% applies. At the federal level, no capital tax is levied. a consequence, Switzerland has two levels of taxation: the
    [Show full text]
  • Taxing Wealth: Evidence from Switzerland
    NBER WORKING PAPER SERIES TAXING WEALTH: EVIDENCE FROM SWITZERLAND Marius Brülhart Jonathan Gruber Matthias Krapf Kurt Schmidheiny Working Paper 22376 http://www.nber.org/papers/w22376 NATIONAL BUREAU OF ECONOMIC RESEARCH 1050 Massachusetts Avenue Cambridge, MA 02138 June 2016 We are grateful to Jonathan Petkun for excellent research assistance, to Etienne Lehmann, Jim Poterba and seminar participants at Bristol, Geneva, Kentucky, MIT and Yale for helpful comments, to the tax administration of the canton of Bern for allowing us to use their micro data for the purpose of this research, to Raphaël Parchet and Stephan Fahrländer for sharing valuable complementary data and to Nina Munoz-Schmid and Roger Amman of the Swiss Federal Tax Administration for useful information. Financial support from the Swiss National Science Foundation (Sinergia grant 147668) is gratefully acknowledged. The views expressed herein are those of the authors and do not necessarily reflect the views of the National Bureau of Economic Research. At least one co-author has disclosed a financial relationship of potential relevance for this research. Further information is available online at http://www.nber.org/papers/w22376.ack NBER working papers are circulated for discussion and comment purposes. They have not been peer-reviewed or been subject to the review by the NBER Board of Directors that accompanies official NBER publications. © 2016 by Marius Brülhart, Jonathan Gruber, Matthias Krapf, and Kurt Schmidheiny. All rights reserved. Short sections of text, not to exceed two paragraphs, may be quoted without explicit permission provided that full credit, including © notice, is given to the source. Taxing Wealth: Evidence from Switzerland Marius Brülhart, Jonathan Gruber, Matthias Krapf, and Kurt Schmidheiny NBER Working Paper No.
    [Show full text]
  • Comparison of Selected Countries © Loyens & Loeff N.V
    2019 Holding Regimes 2019 Comparison of Selected Countries © Loyens & Loeff N.V. 2019 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system or in an automated database or disclosed in any form or by any means (electronic, mechanical, photocopy, recording or otherwise) without the prior written permission of Loyens & Loeff N.V. Insofar as it is permitted, pursuant to Section 16b of the Dutch Copyright Act 1912 (Auteurswet 1912) in conjunction with the Decree of June 20, 1974, Dutch Bulletin of Acts and Decrees 351, as most recently amended by the Decree of December 22, 1997, Dutch Bulletin of Acts and Decrees 764 and Section 17 of the Dutch Copyright Act 1912, to make copies of parts of this publication, the compensation stipulated by law must be remitted to Stichting Reprorecht (the Dutch Reprographic Reproduction Rights Foundation, PO Box 3060, 2130 KB Hoofddorp, the Netherlands). For reproductions of one or more parts of this publication in anthologies, readers or other compilations (Section 16 of the Dutch Copyright Act 1912), please contact the publisher. This publication does not constitute tax or legal advice and the contents thereof may not be relied upon. Each person should seek advice based on his or her particular circumstances. Although this publication was composed with the greatest possible diligence, Loyens & Loeff N.V., the contributing firms and any individuals involved cannot accept liability or responsibility for the results of any actions taken on the basis of this publication without their cooperation, including any errors or omissions. The contributions to this book contain personal views of the authors and therefore do not reflect the opinion of Loyens & Loeff N.V.
    [Show full text]
  • ADECCO GROUP AG (Incorporated with Limited Liability in Switzerland) ADECCO INTERNATIONAL FINANCIAL SERVICES B.V
    ADECCO GROUP AG (incorporated with limited liability in Switzerland) ADECCO INTERNATIONAL FINANCIAL SERVICES B.V. (incorporated with limited liability in The Netherlands) ADECCO FINANCIAL SERVICES (NORTH AMERICA), LLC (incorporated under the laws of the State of Delaware in the United States of America) EUR 3,500,000,000 Euro Medium Term Note Programme unconditionally and irrevocably guaranteed by ADECCO GROUP AG (incorporated with limited liability in Switzerland) Under this EUR 3,500,000,000 Euro Medium Term Note Programme (the Programme), Adecco Group AG (in its capacity as Issuer, Adecco, and in its capacity as guarantor of Notes issued by AIFS or AFS (each as defined below), the Guarantor), Adecco International Financial Services B.V. (AIFS) and Adecco Financial Services (North America), LLC (AFS and, together with Adecco and AIFS, the Issuers, and each an Issuer) may from time to time issue notes (the Notes) denominated in any currency agreed between the relevant Issuer and the relevant Dealer (as defined below). References in this Base Prospectus to the relevant Issuer shall, in relation to any issue or proposed issue of Notes, be references to whichever of Adecco, AIFS or AFS is specified as the Issuer of such Notes in the applicable final terms document (the Final Terms). The payments of all amounts due in respect of the Notes will be unconditionally and irrevocably guaranteed by the Guarantor (except where Adecco is the Issuer). The maximum aggregate nominal amount of all Notes from time to time outstanding under the Programme will not exceed EUR 3,500,000,000 (or its equivalent in other currencies calculated as described in the Programme Agreement described herein), subject to increase as described herein.
    [Show full text]
  • Taxation of Cross-Border Mergers and Acquisitions
    Taxation of cross-border mergers and acquisitions Hungary kpmg.com/tax KPMG International © 2016 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. Hungary Introduction — The profit realized during the sale or in-kind contribution of the so-called ‘reported intangible assets’ (if entitled This overview of the Hungarian regime for mergers to royalty income) is exempt from corporate income tax and acquisitions (M&A) and related tax issues only under certain circumstances. Certain profit from non- discusses statutory frameworks for acquisitions in reported intangible assets may also become tax-exempt. Hungary. It does not consider any specific contractual — The general rate of value added tax (VAT) was increased to arrangements that may affect such transactions. 27 percent, as of 1 January 2012. The primary legislation governing the form and — The concept of real estate investment trusts (REIT) was introduced to the Hungarian legislation, as of 27 July 2011. regulation of companies is ACT V of 2013 on the Civil Code (the Civil Code), effective since 15 March — Withholding tax (WHT) on interest, royalties and certain 2014. As a result of the accession of Hungary to the service fees was abolished as of 1 January 2011. European Union (EU) on 1 May 2004, new forms — As of 1 January 2013, the transfer of a business unit of business associations have been integrated into may be out of scope of VAT if the acquirer meets certain the Hungarian company law legislation, such as conditions prescribed in the Act on VAT.
    [Show full text]
  • Private Client 2018 7Th Edition
    TheICLG International Comparative Legal Guide to: Private Client 2018 7th Edition A practical cross-border insight into private client work Published by Global Legal Group, in association with CDR, with contributions from: Aird & Berlis LLP Maples and Calder Alon Kaplan, Advocate and Notary Law Office Matheson Aronson, Ronkin-Noor, Eyal Law Firm Miller Thomson LLP Arqués Ribert Junyer – Advocats MJM Limited Berwin Leighton Paisner LLP Mori Hamada & Matsumoto Bircham Dyson Bell LLP Mourant Ozannes Cadwalader, Wickersham & Taft LLP New Quadrant Partners Limited DORDA Rechtsanwälte GmbH O’Sullivan Estate Lawyers LLP Griffiths & Partners and Coriats Trust Company Limited Ospelt & Partner Attorneys at Law Ltd. Hassans International Law Firm P+P Pöllath + Partners Higgs & Johnson Rovsing & Gammeljord Holland & Knight LLP Society of Trust and Estate Practitioners (STEP) Katten Muchin Rosenman LLP Spenser & Kauffmann Attorneys at Law Khaitan & Co Studio Tributario Associato Facchini Rossi & Soci (FRS) Lebenberg Advokatbyrå AB Tirard, Naudin, Société d’avocats Lenz & Staehelin Vieira de Almeida Loyens & Loeff Withers Bergman LLP Macfarlanes LLP Zepos & Yannopoulos The International Comparative Legal Guide to: Private Client 2018 General Chapters: 1 BREXIT: The Immigration Implications – James Perrott, Macfarlanes LLP 1 2 Keep Calm and Carry On: The Increasing UK Regulatory and Tax Issues Facing Offshore Trustees – Matthew Braithwaite & Helen Ratcliffe, Bircham Dyson Bell LLP 11 3 Pre-Immigration Planning Considerations for the HNW Client – Think
    [Show full text]
  • Tax Facts 2020
    KPMG Law Advokatfirma Tax Facts 2020 A survey of the Norwegian Tax System February 2020 © 2020 KPMG Law Advokatfirma AS, a Norwegian limited liability company and a member firm of the KPMG network of independent kpmglaw.nomember firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Tax Facts 2020 | KPMG Law Advokatfirma | 1 Contents 1. Controls/restrictions on business 7 1.1. Foreign exchange 8 1.2. Foreign investor participation 8 1.3. Takeovers, mergers and acquisitions 8 2. Corporate Taxation 11 2.1. Overview 12 2.2. Residence 12 2.3. Income Liable to Tax 12 2.4. Deductions 12 2.5. Gain/loss on realisation of assets 14 2.6. The exemption method for dividend and gains 14 2.7. Double tax relief (DTR) 16 2.8. Losses 18 2.9. Grouping/consolidated returns 18 2.10. Tax rates 19 2.11. General anti-avoidance standard 19 2.12. Special anti-avoidance clause 19 2.13. Controlled foreign company (CFC) 19 2.14. Transactions between related parties 20 2.15. Transfer pricing 21 2.16. Limitations of tax deductibility for interest expenses 22 2.17. Taxes on undistributed profits 25 2.18. Exit tax 25 2.19. The petroleum tax system 25 2.20. Taxes and fees in the power sector 28 2.21. Tonnage tax 30 2.22. Branches / permanent establishments in Norway 31 2 | Tax Facts 2020 | KPMG Law Advokatfirma 2.23. Tax liability under domestic law and permanent establishment 31 2.24. Branch versus subsidiary 32 2.25. Formal requirements and procedures 32 2.26.
    [Show full text]
  • Behavioral Responses to Wealth Taxes: Evidence from Switzerland*
    Behavioral Responses to Wealth Taxes: Evidence from Switzerland* Marius Brülhart† Jonathan Gruber‡ Matthias Krapf§ University of Lausanne MIT University of Lausanne Kurt Schmidheiny¶ University of Basel October 10, 2019 Abstract We study how reported wealth responds to changes in wealth tax rates. Exploiting rich intra-national variation in Switzerland, the country with the highest revenue share of an- nual wealth taxation in the OECD, we find that a 1 percentage point drop in the wealth tax rate raises reported wealth by at least 43% after 6 years. Administrative tax records of two cantons with quasi-randomly assigned differential tax reforms suggest that 24% of the effect arise from taxpayer mobility and 20% from house price capitalization. Savings re- sponses appear unable to explain more than a small fraction of the remainder, suggesting sizable evasion responses in this setting with no third-party reporting of financial wealth. * Previous versions of this paper circulated under the titles ‘The Elasticity of Taxable Wealth: Evidence from Switzerland’ and ‘Taxing Wealth: Evidence from Switzerland’. This version is significantly extended in terms of both data and estimation methods. We are grateful to Jonathan Petkun for excellent research assistance, to Etienne Lehmann, Jim Poterba, Emmanuel Saez, and seminar participants at the Universities of Barcelona, Bristol, ETH Zurich, GATE Lyon, Geneva, Kentucky, Konstanz, Mannheim, MIT, Yale and numerous conferences for helpful comments, to the tax administrations of the cantons of Bern and Lucerne for allowing us to use anonymized micro data for the purpose of this research, to Raphaël Parchet, Stephan Fahrländer and the Lucerne statistical office (LUSTAT) for sharing valuable complementary data, and to Nina Munoz-Schmid and Roger Amman of the Swiss Federal Tax Administration for useful information.
    [Show full text]
  • Taxation and Investment in Hungary 2015 Reach, Relevance and Reliability
    Taxation and Investment in Hungary 2015 Reach, relevance and reliability A publication of Deloitte Touche Tohmatsu Limited Contents 1.0 Investment climate 1.1 Business environment 1.2 Currency 1.3 Banking and financing 1.4 Foreign investment 1.5 Tax incentives 1.6 Exchange controls 2.0 Setting up a business 2.1 Principal forms of business entity 2.2 Regulation of business 2.3 Accounting, filing and auditing requirements 3.0 Business taxation 3.1 Overview 3.2 Residence 3.3 Taxable income and rates 3.4 Capital gains taxation 3.5 Double taxation relief 3.6 Anti-avoidance provisions 3.7 Administration 3.8 Other taxes on business 4.0 Withholding taxes 4.1 Dividends 4.2 Interest 4.3 Royalties 4.4 Branch remittance tax 4.5 Wage tax/social security contributions 5.0 Indirect taxes 5.1 Value added tax 5.2 Capital tax 5.3 Real estate tax 5.4 Transfer tax 5.5 Stamp duty 5.6 Customs and excise duties 5.7 Environmental taxes 6.0 Taxes on individuals 6.1 Residence 6.2 Taxable income and rates 6.3 Inheritance and gift tax 6.4 Net wealth tax 6.5 Real property tax 6.6 Social security contributions 6.7 Other taxes 6.8 Compliance 7.0 Labor environment 7.1 Employee rights and remuneration 7.2 Wages and benefits 7.3 Termination of employment 7.4 Labor-management relations 7.5 Employment of foreigners 8.0 Deloitte International Tax Source 9.0 Contact us Hungary Taxation and Investment 2015 1.0 Investment climate 1.1 Business environment Hungary is a parliamentary democracy with a unicameral parliament called the National Assembly.
    [Show full text]
  • Incentives and Taxes in the Netherlands 2021
    Incentives and taxes 2021 The Netherlands January 2021 Stimulating Foreign Investment and Entrepreneurship Table of contents Introduction 4 Attractive Features 4 Competitive statutory corporate income tax rate 5 Innovation Box: effective tax rate of 9% 5 Participation Exemption: drive for European headquarters 6 Fiscal Unity Regime: consolidated tax returns 6 Losses: carry-back for one year and carry-forward for six years 6 Ruling Practice: certainty in advance 7 Transfer Pricing: arm’s length principle 7 R&D wage tax deduction (WBSO): incentive to invest in R&D 7 MIA and Vamil: tax relief schemes for environmentally friendly investments 8 Energy Investment Allowance (EIA): tax relief program for sustainable energy 8 30% facility: special tax regime for expats 9 Wide Tax Treaty Network: avoidance of double taxation 9 Treaty-based tax rate reductions 10 VAT reverse charge mechanism on import: cash-flow advantages 10 Dutch Tax Authorities: easy access to the tax inspector 11 Dutch Customs Authorities: practical and pro-active approach 11 3 Introduction With a competitive corporate income tax rate in Europe—15% on the first € 245,000 and 25% for taxable profits exceeding € 245,000—as well as a number of attractive incentive programs, the Netherlands offers a supportive fiscal climate for international companies. The Netherlands offers a wide tax treaty network, special measures for highly skilled expats and certainty in advance of future tax positions—just a few of the features that help multinational companies to thrive in the Netherlands.
    [Show full text]
  • A09029279 V2.0 Cleanlevel 2 Prospectus Call Options
    Credit Suisse International (registered as an unlimited liability company in England and Wales under No. 2500199) Principal Protected Securities and Non-Principal Protected Securities (Base Prospectus BPCSI-1) (Call Options and Put Options) Pursuant to the Structured Products Programme Under this Base Prospectus, Credit Suisse International (the “ Issuer ”) may issue Securities (“ Securities ”) on the terms set out herein and in the relevant Final Terms. This document constitutes a base prospectus (the “ Base Prospectus ”) prepared for the purposes of Article 5.4 of Directive 2003/71/EC (the “ Prospectus Directive ”). The Base Prospectus contains information relating to the Securities. The Base Prospectus shall be read in conjunction with the documents incorporated herein by reference (see the section entitled “Documents Incorporated by Reference”). This document has been filed with the Financial Services Authority in its capacity as competent authority under the UK Financial Services and Markets Act 2000 (the “ UK Listing Authority ”) for the purposes of the Prospectus Directive. The Issuer has requested the UK Listing Authority to provide the competent authorities for the purposes of the Prospectus Directive in Austria, Belgium, Finland, France, Germany, Ireland, Italy, Luxembourg, The Netherlands, Norway, Spain and Sweden with a certificate of approval in accordance with Article 18 of the Prospectus Directive attesting that this Base Prospectus has been drawn up in accordance with the Prospectus Directive. The final terms relevant to an issue of Securities will be set out in a final terms document (the “ Final Terms ”) which will be provided to investors and, in the case of issues for which a prospectus is required under the Prospectus Directive, filed with the Financial Services Authority and made available, free of charge, to the public at the registered office of the Issuer and at the offices of the relevant Distributors and Paying Agents.
    [Show full text]