Section 57 para. 3 StG ZH was adapted to the corresponding provision in the law on direct federal tax with effect from 01 January 2021.
In the case of companies domiciled in Switzerland with permanent establishments abroad, tax will now be allocated according to the direct object method, as is the case with the Swiss Confederation.
Losses can be provisionally absorbed if they have not already been taken into account in the permanent establishment state. The loss transfer must be applied for by the company concerned for each tax period.
The whole changeover is accompanied by transitional arrangements.
Further information can be found here.
