At its meeting on 4 May 2022, the Federal Council approved the amendments, which will enter into force on 1 January 2023.

Accordingly, the participation quota above which the notification procedure for withholding tax is permissible in the group (currently 20%) is to be reduced to 10%. In these cases, tax payment with subsequent refund can be waived. In addition, the reporting procedure should in future be possible not only for corporations or cooperatives, but for all legal entities that hold a qualifying participation. Furthermore, the authorisation to be obtained in international circumstances will be valid for five years instead of three. The safeguarding function of the withholding tax will be preserved and the innovation will have only a minor financial impact. Furthermore, the extension of the notification procedure reduces the administrative burden for companies and tax authorities.

The media release and additional documents are available here.