Switzerland Readies Guidance on Carried Interest
![Switzerland Readies Guidance on Carried Interest](https://cdn.prod.website-files.com/5ee2325b4f503b301b89d304/610913e4e1cb48fecfc5e75d_image15.jpg)
Before the entry into force in 2007 of Switzerland’s new Federal Act on Collective Investment Schemes (CISA), which introduced the Swiss limited partnership for collective investments (Swiss-LP),1 Switzerland never had an officially published practice on the treatment of distributed carried interest in the hands of fund managers for Swiss income tax purposes because the Swiss-LP was simply not foreseen under Swiss law.
Of course, the issue already existed before the introduction of the CISA — for example, in an international context where a Swiss resident person acts as a manager of a foreign limited partnership (LP) — but the need for a consistent and harmonized approach had not been identified as yet. Instead, the cantons were more or less free to rule on matters on a case-bycase basis. (...)