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  • Service: Tax, International Tax
  • Type: Regulatory update
  • Date: 3/7/2014

Switzerland - New rules on “principal companies” may require action 

March 7:  Guidelines issued by the Swiss federal tax administration concern the taxation of “principal companies” and could affect principal company structures.

Central to the Swiss principal company structure is the international allocation of profit between the principal company and the foreign distribution companies, whereby a certain part of the distribution profit is regarded as not taxable in Switzerland.


The new guidelines introduce new, more stringent conditions that must be satisfied in order to apply the Swiss principal companies regime.


Read a March 2014 report prepared by the KPMG member firm in the Netherlands: Action required: new rules on Swiss Principal Companies




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