At its meeting on 10 March 2017, the Swiss Federal Council decided to strengthen the financing activities of groups of companies in Switzerland and approved the amendment to the Withholding Tax Ordinance. The amendment shall enter into force on 1 April 2017.

According to a press release of the Federal Department of Finance (FDF) dated 10 March 2017, the amended Ordinance on Withholding Tax (VStV) affects those groups in which a domestic group company (guarantor) guarantees a bond of a foreign group company (issuer) belonging to the same group. A transfer of funds of the foreign issuer to a group company domiciled in Switzerland will be possible at most to the extent of the issuer's equity capital, without the interest thereon being subject to withholding tax.

The following documents were published: (1) Amendment of the Ordinance on Withholding Tax (VStG); (2) Report on the results of the consultation procedure on the amendment of the Ordinance on Withholding Tax (Group Financing); (3) Explanatory Notes on the amendment of the Ordinance on Withholding Tax (Group Financing).