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5.2. Treatment of Foreign Profits / Losses

Foreign profits of the resident entity are not included in the overall taxable income, provided that those profits are attributable to foreign business operations, permanent establishments or real estate.

Losses from foreign PEs may be deducted from the Swiss income tax base on a provisional basis. In case that these losses can be offset against profits in the foreign PE within the seven subsequent years the Swiss income tax base will be amended accordingly.