In conclusion, the tax charge for corporations differs in every canton of Switzerland. However, in an international context, the tax charge is very low.
Foreign withholding tax Switzerland has concluded double taxation treaties with many other countries. In most cases it is possible for the Swiss beneficiary of a payment charged with foreign withholding tax to reclaim that tax at least partially. Several double tax treaties (e.g., with Germany, France, Italy and Belgium) require special conditions to be met before a refund of the foreign withholding tax can be granted. A refund is guaranteed only when the Swiss recipient is taxed at full rates in Switzerland. For an operating company there are no problems in this respect because it is taxed at full rates at the federal as well as at on the cantonal level.
In addition to the provisions of all double tax treaties entered into by Switzerland, the regulations of the Swiss Misuse Decree have to be met in order to receive the foreign withholding tax refunded. The Misuse Decree is an internal law of Switzerland designed to avoid the abuse of double tax treaties.
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