argomento: News del mese - Diritto Internazionale e Comunitario

Articoli Correlati: Switzerland - foreign company - fiscal news

From the 1^st January 2020, foreign companies will be able to take advantage of the new “Step-up upon Migration”, which consists of a fiscally neutral increase in the so-called “built-in gains” at fair market value, for the purposes of Direct taxation in Switzerland, when these companies move their registered office, permanent establishment or assets, business units and activities carried out from abroad to Switzerland. The built-in gains could be depreciated for tax purposes for a certain reference period, allowing the Swiss company or a subsidiary to significantly reduce its tax burden during that period. This system is a very interesting tool, together with other tax measures such as the Patent box or the R&D super deductions introduced with the implementation of the Swiss corporate tax reform of 1^st January 2020, contributing substantially to maintaining and relaunching the international appeal of the Switzerland as a place to establish the business.