The participation deduction has the effect of largely exempting certain dividends and capital gains from the disposal of these participations from tax within the Group. This prevents multiple taxation of the same profits within the group. However, this participation deduction differs from systems in other countries. The OECD also provides for a different system for the global minimum tax. This can lead to over- or under-taxation for companies affected by the minimum tax.
The FDF therefore intends to review the participation deduction as part of the minimum tax legislation. According to the transitional provision in the constitution, the Federal Council must submit the bill to parliament no later than six years after the ordinance on OECD minimum taxation comes into force.
Further information on motion 18.3718 (calculation of the participation deduction) is available here.
