Too big to fail: Revised Withholding Tax Act in force from 2013

Bern, 31.10.2012 - Interest paid on the contingent convertible bonds (CoCos) of systemically important banks and on write-down bonds will be exempt from withholding tax from 1 January 2013. The Federal Council decided to bring the corresponding amendments to the Withholding Tax Act into force on that date.

The tax framework for issuing CoCos and write-down bonds should be improved with the Withholding Tax Act amendment approved by parliament on 15 June 2012. This will facilitate the implementation of the capital requirements for systemically important banks as provided for in the Banking Act's "too big to fail" bill.

In order to be exempt from withholding tax, these bonds must meet the relevant conditions under supervisory law and have been explicitly approved by the Swiss Financial Market Supervisory Authority for counting towards the capital requirements. Withholding tax exemption for CoCos and write-down bonds will be restricted to bonds issued between 2013 and 2016.

Address for enquiries

Urs Jendly, Federal Tax Administration
+41 31 322 73 35,


The Federal Council

Federal Department of Finance