PCP
A targeted reform
The system covers large international groups with annual worldwide revenue of at least 750 million euros. The 15 per cent minimum applies to profit calculated under international rules. It is not a new uniform rate for every Swiss small business. Nor does a published cantonal rate alone show a group’s entire effective tax burden.
A nominal rate and effective taxation answer different questions. The rules determine which profits and taxes enter the calculation. Describing the reform as a simple increase in one national schedule conceals its mechanism.
Who collects the top-up?
One purpose of the 2023 vote was to allow Switzerland to collect a top-up that, in certain circumstances, could otherwise be collected abroad. The argument concerns interacting taxing rights, not an assumption that profit disappears whenever a canton taxes lightly.
The finance department’s dossier, published in September 2024, sets out the sequence: domestic top-up tax from 1 January 2024, followed by the income inclusion rule from 1 January 2025. The latter addresses undertaxed profits of foreign group entities under the framework. These developments followed the vote; they were not receipts already collected in June 2023.
The top-up is a federal tax administered by the cantons. The authority establishing the tax claim and the administration implementing it therefore operate at different levels. Expertise and consistent interpretation matter. Ambitious rules do not automatically generate revenue if returns cannot be checked.
Additional revenue can serve opposing choices
Minimum taxation limits one form of competition through low effective taxation for covered groups. It does not abolish competition between locations. That competition can shift towards subsidies, dedicated infrastructure or other benefits. A larger tax payment followed by new support for the same beneficiary can substantially change the net public gain.
Spending therefore deserves as much scrutiny as receipts. Schools, public transport and training benefit diverse people and activities. Targeted compensation concentrates the return more narrowly. Both can be debated, but they are not socially equivalent simply because each is described as supporting attractiveness.
The employment objection deserves a concrete answer. Available skills, reliable networks and good public services also support production. Preserving activity does not require automatically returning every new tax franc to companies. Targeted advantages should be compared with investment shared across the economy.
A forecast is not a collection
In April 2023, the department presented revenue estimates and their uncertainties. Profit developments, company responses and implementation abroad could change the result. The original estimate must not retrospectively be described as money collected. Tax year, assessment and actual payment must also be distinguished.
For the PCP, additional taxation should fund collective needs, with clear publication of distribution and use. Lasting commitments require a prudent base, while less well-resourced regions must enter the decision. The vote opened an instrument; equity depends on tax enforcement, territorial solidarity and subsequent choices.