EU removes Switzerland from the “Grey List” - Tax and Legal blog


The Economics and Finance Ministers of the EU member states decided at their meeting on 10 October 2019 to remove Switzerland from their so-called EU “Grey List”.

Switzerland has been included on the EU “Grey List” of third countries which had committed themselves to complying with international tax standards, but had not yet fully implemented such standards, since 2017.

As early as October 2014, Switzerland and the 28 EU member states signed a mutual understanding on corporate taxation, which provided for the abolition of specified tax regimes by Switzerland. In return, the EU member states reaffirmed their intention to repeal any countermeasures, once these regimes were abolished.

In May 2019, the Swiss voter approved the Federal Act on Tax Reform and AHV Financing (TRAF) with over 66% of yes votes. With the enactment of TARF, Switzerland will abolish tax regimes no longer compatible with international standards as of 1 January 2020, such as the mixed or holding company regimes. The law, in turn, introduces internationally accepted tax measures such as a patent box, and provides for a broad based reduction of headline tax rates by individual cantons to ensure that Switzerland becomes even more attractive for international and domestic companies alike.

With the approval of TRAF, Switzerland is honouring the commitment it entered into with the agreement signed in 2014 and can therefore be removed from the “Grey List”.

The removal will enter into force upon publication of the revised Annexes in the Official Journal of the EU.

The removal of Switzerland from the EU “Grey List” is great news in particular for multinational companies already operating from Switzerland or considering migrating headquarter, IP, finance or other operations to Switzerland, it is a further step in making Switzerland even more attractive for both international and domestic companies.

If you would like to discuss more on this topic, please do reach out to our key contacts below.

Key contacts


Jackie Hess - Managing Partner, Tax & Legal

Jackie is the Managing Partner for Tax & Legal and a member of the Swiss Executive team. She has more than 20 years of experience serving some of Deloitte’s largest multinational clients. Her areas of focus include business model optimization in the BEPS era, Swiss ruling and tax holiday negotiations, tax controversy, and audit defense. In addition, she has extensive experience in cross-border tax planning including substance reviews, IP structuring, and finance planning. Jackie’s industry focus is life sciences where she advises predominately US-listed companies in the biotech and medtech space that have their European headquarters in Switzerland.


Raoul Stocker_BLOG

Raoul Stocker - Partner, Business Tax Leader Zurich

Raoul Stocker is a tax partner with more than 15 years’ experience specifically in international tax litigation such as mutual agreement procedures and advanced pricing agreements. His focus lies on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing as well as taxation of financial institutions. Raoul is also a lecturer of transfer pricing and tax law at the University of St. Gallen.


Jacques Kistler

Jacques Kistler - Partner, International Tax

Jacques is the Lead Partner of our Corporate Tax service line in the French Speaking part of Switzerland, covering international tax and M&A. He has been a full time International Corporate Tax specialist for over 23 years.


Rene Zulauf

René Zulauf - Partner, International Tax

René has 20 years of experience in the field of international tax structuring, financial services tax and Mergers & Acquisitions. He specializes in cross-border tax planning and has assisted numerous multinationals in particular in the establishment of Swiss finance and IP structures, as well as in the structuring of Swiss trading and principal/headquarter operations.



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