Corporate Taxation

Switzerland is finally to receive a tonnage tax

On May 4, 2022, the Federal Council adopted the dispatch on the Federal Tonnage Tax Act for the attention of parliament. The bill provides that profits from the operation of seagoing vessels will in future be taxed at federal, cantonal and municipal level on the basis of the net tonnage (cargo capacity) of the vessels and not on the basis of the net profit of the shipping company. This creates an attractive tax base for profitable companies compared to the net profit under commercial law. For environmentally friendly ships, an additional rebate of up to 30% is envisaged.

According to the bill, the tonnage tax can be applied optionally for each seagoing vessel for a period of ten years. A change to the ordinary profit taxation before the expiry of ten years shall be possible; however, a re-entry into the tonnage regime will only be permitted in the sixth year after the exit.

According to the bill, inland shipping and pure river shipping do not qualify for the tonnage tax.

The tonnage tax as a support instrument for maritime shipping is widely accepted internationally and particularly widespread in the EU. With the bill, the Federal Council is now creating a level playing field with other countries for the Swiss deep-sea fleet and the various international shipping companies domiciled in Switzerland.

Compared to the preliminary draft of the bill, the Federal Council has made various improvements that make the tonnage tax more attractive for the industry. In the preliminary draft, it was still a prerequisite that at least 60% of the tonnage of ocean-going vessels must sail under the Swiss or EEA flag. Now it is only required that the flag of the ships concerned belongs to a country that is subject to the four relevant international maritime conventions (SOLAS, MARPOL, STCW and MLC).

It is unclear if and when the bill will enter into force.