Switzerland: Consultation on proposal to introduce qualified refundable R&D tax credit (canton of Lucerne)
Consultation process will run until June 9, 2025
The Swiss canton of Lucerne on March 10, 2025, launched a consultation on a proposal to introduce new tax incentives in light of the implementation of Pillar Two.
According to the release (German), the canton plans to enhance innovation and research and development (R&D) by providing a tax credit with respect to the following types of expenses:
- 30% for R&D personnel (gross salary)
- 20% for investments (depreciation)
- 10% for contract research
The tax credit would be designed to qualify as a qualified refundable tax credit (QRTC) for Pillar Two purposes and would be subject to an annual maximum amount to be set by the Cantonal Council. For 2026, the release expects a cap at CHF 160 million (approximately €166 million).
According to the release, the consultation process will run until June 9, 2025, and the rules would come into force on October 1, 2026, at the earliest.
The canton of Lucerne is the fourth Swiss canton that has published a proposal for the introduction of incentives aligned with the Pillar Two rules (after the cantons of Grisons, Zug and Basel-Stadt).
Read a March 2025 report prepared by KPMG’s EU Tax Centre