Tax Reform (TRAF)

Tax Reform and AHV Financing, USR III / SV17, Planning Options, Opportunities & Risks

Your goals

Following the failure of Corporate Tax Reform III two years ago, the Swiss people adopted the Federal Act on Tax Reform and AHV Financing (TRAF; in German STAF) on 19 May 2019.

The TRAF will come into force on 1 January 2020 and will have a major impact on the tax burden on companies and permanent establishments in Switzerland. In addition, the parameters for the attractiveness of Switzerland and the cantons as a business location will change. Established business models must be reviewed from a tax point of view and challenged regarding their tax efficiency.

With TRAF, Switzerland meets all OECD and EU standards and remains a very attractive and successful location to do business. Against the background of the rapidly changing Swiss tax landscape and international developments in corporate taxation, however, there is a constant need for action. Today, even more than in the past, a robust national and international tax structure must be underpinned by a well-thought-out defence strategy.

Our services

Companies and permanent establishments which are subject to the cantonal holding, domicile or mixed company privileges must reconsider the impact of the TRAF on their tax burden. Now is also right the time to reasses the group structure and the most favourable business location within Switzerland. Consolidation or transfer of the substance to another canton can create both operational and tax added value.

The MME TRAF assistance includes:

  • STAF-Workshops for management and board members
  • Business model review from a national and international tax perspective
  • Analyse and calculation of the effects of the Swiss Patentbox
  • Analyse and calculation of the impact of the Swiss R&D super-deduction
  • Analyse and calculation of the impact of a step up including valuations for tax purposes
  • Redesign of Financing / Treasury Center Functions
  • Location consulting taking into account all relevant factors including taxes
  • Project management regarding the implementation of new structures

MME Integrated Approach

TRAF may lead to changes regarding the corporate structure and the business model in Switzerland and abroad. This often includes corporate and labour law aspects and existing contracts need to be adapted. In addition, the TRAF and international developments give cause to rethink the corporate governance of a group. MME has proven experts in all these areas as well.


  • Thomas Linder,

    Fredrik Dekker

    Novità fiscali: L'attualità del diritto tributario svizzero e internazionale


  • Dr. Luka Müller,

    Thomas Linder

    Digitale Revolution im Banking


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