Tax Newsletter September 2019 - IFA country report 2019: Analysis of Swiss interest deductibility restrictions from the perspective of BEPS Action 4

As part of the IFA Congress 2019 held in London, the authors discuss BEPS Action 4 (interest deductibility) and its implementation in Switzerland. Interest limitation rules, as the ones proposed in BEPS Action 4 or ruled in the ATAD of the European Union, have not been discussed intensively in Switzerland. Nevertheless, Switzerland has known thin capitalisation rules for more than 20 years and has established own regulations to prevent base erosion and profit shifting. As far as the authors observe, there is no intention by the Swiss legislator to change the current rules and implement new ones.