In a referendum held on May 19 2019, the Federal Act on Tax
Reform and AHV Financing (TRAF) was adopted by the Swiss people and
the cantons. The reform includes several measures directed at
corporate income taxation, such as the abolition of tax privileges
for certain types of companies (status companies) and the
implementation of internationally accepted replacement measures
such as a patent box or the ability to super-deduct R&D costs
(up to 150% of actual costs). The reform also contains tax measures
at the shareholder level. The majority of the measures will be in
force as of January 1 2020.
Capital contribution principle
The most relevant change regarding the taxation of dividends and
share buybacks including the withholding tax consequences is the
implementation of restrictions on the capital contribution
principle (CCP). The CCP , which was implemented in Swiss tax laws
as of January 1 2011, stipulates that the repayment of capital
contributions made after
