Preservation of the Geneva municipal business tax following TRAF implementation

At the municipal business tax level (hereinafter referred to as 'MBT'), such companies benefited from special arrangements for determining taxable turnover, in order to adapt their privileged tax regime as faithfully as possible to the specific features of that tax. Thus, these taxpayers were subject to preferential taxation on the portion of their turnover generated abroad or exempted from tax.

Notwithstanding the abolition of the privileged tax regimes for cantonal and communal taxes, the general principles of MBT taxation for holding and auxiliary companies will remain similar to those applicable until now.

An application circular planned for autumn is currently being drafted and will replace Communication n°1/99 regarding the taxation rules for companies with privileged tax regimes. It will set out the application conditions and the tax arrangements for companies which, until December 31^st, 2019, benefited from the preferential tax rules for auxiliary or holding companies provided for in the Law on the taxation of legal persons.

Article written by Jean Gafan and Nathalie Pellanda Gaud