Switzerland as a Business Location & Swiss Taxation

International tax competition and competition between business locations have changed fundamentally. Switzerland is coming under increasing pressure as key instruments of its existing location policy have lost effectiveness. A new legal opinion by Prof. Dr Robert J. Danon and Prof. Dr Pascal Hinny shows how Switzerland can restore its tax attractiveness by making use of the new international framework and strengthening tax incentives for research, development and innovation in a targeted manner.

Yesterday, the Federal Council published the amendments to the Capital Adequacy Ordinance and the dispatch on the revision of the Banking Act. SwissHoldings supports the goal of a stable financial system. At the same time, the impact on companies and the Swiss financial centre must be carefully considered. The association’s member companies are dependent on internationally competitive banks and an attractive capital market. Balanced and internationally harmonised regulation is an important locational advantage. However, the current draft goes beyond international regulatory standards and would have a negative impact on the economy as a whole.

In an increasingly uncertain international environment, the question of how to create a reliable and innovation-friendly regulatory framework is gaining importance. The first edition of the SwissHoldings Legal Talks, held on March 26, 2026, in Bern, focused on the topic “The Legal Environment as a Location Factor: Targeted Reforms for a Competitive Switzerland.” Legal certainty is a central prerequisite for investment, innovation, and long-term location decisions.

With the Side-by-Side package, the OECD is strengthening the minimum taxation while offering new flexibilities. US companies are effectively exempted through recognition of the American system. Other countries can benefit from administrative simplifications and the new possibility of substance-based tax credits. The package offers opportunities for Switzerland, as it allows for OECD-compliant deductions of wage costs and investments. The question now is what tax policy strategy it intends to pursue in international competition.

The Council of States has approved the motion on “Legal certainty in the implementation of the OECD minimum tax,” after the National Council had already endorsed an identical motion at the beginning of the week. The motions pose serious risks for Switzerland as a business location and for Swiss companies. SwissHoldings is therefore calling for forward-looking, internationally compatible implementation and targeted measures to strengthen Switzerland’s attractiveness as a business location in the long term.