Switzerland: Possible referendum on reform of withholding and stamp taxes

A reform of the Swiss withholding tax and stamp tax legislation

A reform of the Swiss withholding tax and stamp tax legislation

The Swiss Parliament in late December adopted a reform of the withholding tax and stamp tax legislation which is set to enter into force on 1 January 2023. The reform includes, among other measures, these proposed changes:

  • Interest on Swiss bonds issued on or after 1 January 2023, and distributions of qualifying interest from Swiss investment funds, would no longer be subject to 35% withholding tax
  • Manufactured payments on an underlying Swiss source of income would be subject to 35% withholding tax, even if the payor is a non-Swiss entity
  • Transactions in domestic bonds, the issuance of units in qualifying foreign money market funds and the transfer of equity investments of more than 10%, would no longer be subject to stamp tax.

However, a referendum campaign has been launched against this reform, and 50,000 signatures must be collected by 6 April 2022 to file the referendum request. If the deadline is met and a public referendum is called, the withholding tax and stamp tax reform would not be effective 1 January 2023. The public vote would likely not take place until 2023, meaning the reforms would not be able to enter into force before 1 January 2024 (if approved).

Read a February 2022 report prepared by the KPMG member firm in Switzerland


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