Switzerland:
Tax Newsletter September 2019 – IFA Country Report 2019: Analysis Of Swiss Interest Deductibility Restrictions From The Perspective Of BEPS Action 4
02 October 2019
Prager Dreifuss
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As part of the IFA Congress 2019 held in London, the authors
discuss BEPS Action 4 (interest deductibility) and its
implementation in Switzerland. Interest limitation rules, as the
ones proposed in BEPS Action 4 or ruled in the ATAD of
the European Union, have not been discussed intensively in
Switzerland. Nevertheless, Switzerland has known thin
capitalisation rules for more than 20 years and has established own
regulations to prevent base erosion and profit shifting. As far as
the authors observe, there is no intention by the Swiss legislator
to change the current rules and implement new ones.
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