Switzerland Fact-File Part 2:
Individual Business Domestic Taxation
2.6 Switzerland Partnership Income Taxation
The Tax Treatment of General and Limited Partnerships
Partnerships in Switzerland may be treated as an entity or
as a business run by individual partners and may be general
or limited partnerships. The essential difference is in apportioning
income and tax liability. In the so-called ‘entity model’,
the partnership is treated as a separate legal entity (Limited
Partnership), whereas in the second option (known as the flow-through
model) income, and therefore tax liability, is attributed
to the partners (General Partnership). A partnership can also
be a foreign partnership as this is permitted under Swiss
law.
With a general partnership, income is attributed to each
partner and is apportioned according to the investment in
the partnership. Each partner is responsible for filing his
or her own personal tax return and tax is paid at personal
income tax rates. Partners are classed as self-employed and
may deduct any losses, or proportion of partnership losses,
before establishing their own taxable base.
In a limited partnership, the partnership is itself a separate
legal entity and tax is paid at corporate income tax rates
– partners are jointly and severally liable for tax
and other debts of the partnership.
A partner may either be an individual or a company (corporation)
and will be liable to pay tax at the appropriate rate (income
tax or corporate tax).
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