IP Box

The Walden Company takes advantage of the progressive tax laws and IP Box concept offered by the Canton of Nidwalden. Businesses setting up a physical office with employees in one of the “gemeinde” (towns, communes or municipalities) of Nidwalden are eligible for very low corporation taxes.

The Walden Company provides all the personal, offices, and materials as a basis to our clients to benefit from the tax advantages offered in Nidwalden.

As of 1 January 2011, the Canton of Nidwalden introduced a new law which reduces the cantonal tax rate on net licence income by 80%. The “IP Licence Box” system is unique in Switzerland and further strengthens the position of Nidwalden and Switzerland as a highly attractive business and research location.

Including federal tax, an effective corporate income tax rate of 8.8% is levied on net licence income. The reduced tax rate applies to net licence income from ‘old’ IP (held prior to 1 January 2011) and ‘new’ IP, to self-developed and acquired IP, from both third parties and group companies. It is not relevant whether the licence payments are Swiss or foreign sourced. Furthermore, capital gains on the sale of IP also qualify as licence income.

The definition of licence income is equivalent to Art. 12 Para. 2 of the OECD Model Convention. License income includes payments of any kind received as a consideration for the use of or the right to use any:

  • Copyright of literary, artistic or scientific work including cinematograph films
  • Patents
  • Trademarks
  • Design or model
  • Plans
  • Secret formula or process
  • Information concerning industrial, commercial or scientific know how

Compared to rules in other countries, the definition of licence income is very wide.