Although the (new) measures may be applied in combination, the tax reform provides for minimum taxation of 30%. The patent box, the additional R&D deduction, the NID and depreciation in connection with a step-up (current law step-up) may reduce the profit (before deduction of these measures, before loss carryforwards and excluding net participation income) by a maximum of 70%. The cantons have the option of providing for a higher minimum taxation when transposing these measures into cantonal law. Surpluses resulting from this restriction cannot be carried forward. Certain details of this relief limit are currently still unclear and need to be defined by the authorities within the framework of implementing provisions.
Overall limitation of measures
By Olivier Eichenberger, 28.09.2018