On 19 May 2019, Swiss voters approved, by 66.4%, the Federal Act on Tax Reform and AHV Financing (TRAF/RFFA). This hybrid package links two intrinsically unrelated objects: a reform of corporate taxation and an annual injection of around 2 billion francs into the old-age insurance (AHV/AVS).
TRAF rose from the ashes of Corporate Tax Reform III, sharply rejected in February 2017 (59.1% no). To push through the abolition of the special tax statuses — long criticised by the OECD and the EU as unfair —, Parliament this time attached the reform to a social component: every franc of tax revenue lost would be offset by a franc paid to the AHV. A compromise nicknamed « Kuhhandel » (horse-trading) by its detractors.
The stakes were twofold: securing international compliance and the attractiveness of Switzerland as a business location on one hand, shoring up a financially fragile AHV on the other. The reform also introduced new tax instruments (patent box, deductions for research and development, disclosure of hidden reserves).
On 19 May 2019, the yes prevailed widely with 66.4% of the vote, on a turnout of 43.7%. Notably, the reform was accepted by all cantons.
▲ Cantons that accepted All 26 cantons, without exception, accepted the reform — from Zug (68.6%) across all of German-speaking Switzerland and Ticino to French-speaking Switzerland. | ▼ Cantons that rejected None. TRAF secured a majority in every canton — a fairly rare outcome for a tax measure. |
Actors and personalities
▲ Yes camp • Federal Council (Ueli Maurer, Finance Minister) • FDP, The Centre / CVP (support for the tax component) • SP (won over thanks to the AHV component) • Economiesuisse, Employers' Association (business circles) • SGB and several trade unions (swayed by the 2 billion for the AHV) | ▼ No camp • The Greens (against the coupling and the new reliefs) • Left of the left (PdA, solidaritéS) • Part of the socialist base (divided over the compromise) • SVP (officially neutral / divided, critical of the AHV component) |
Arguments and verdicts
▲ Arguments FOR (Yes camp) Abolishing special statuses preserves attractiveness « The special regimes are no longer tolerated internationally; abolishing them while lowering ordinary rates safeguards jobs and revenues. » — Federal Council, 2019 ✓ Argument confirmed The privileged tax statuses were indeed abolished on 1 January 2020. The cantons lowered their ordinary rates and Switzerland remained a competitive location; it later adopted the OECD minimum tax of 15% (voted in 2023, in force from 2024). Source: FTA / FDF; OECD, implementation 2020-2024. The reform shores up the AHV « The social component will bring the old-age insurance around 2 billion francs a year. » — Committee « Yes to TRAF », 2019 ✓ Argument confirmed The additional AHV financing, of around 2 billion francs a year, came into force as early as 2020, temporarily relieving the insurance's accounts before the AHV 21 reform. Source: FSIO; AHV accounts 2020-2021. | ▼ Arguments AGAINST (No camp) An unnatural coupling that violates the unity of subject matter « Linking corporate taxes and the AHV is an unconstitutional blending of issues. » — Left-wing opponents / Young SVP, 2019 ✗ Argument refuted The appeals lodged (notably from Vaud and Neuchâtel) against the validity of the result were dismissed. The coupling was deemed admissible and the reform entered fully into force. Source: appeal rulings 2019; Federal Chancellery. Old privileges replaced by new ones « Patent box and R&D deductions create new tax niches benefiting large companies. » — The Greens, 2019 ✓~ Partly confirmed New preferential instruments (patent box, R&D deductions) were indeed introduced, as announced. The expected tax losses (around 2 billion) materialised, partly offset by dynamic effects in several cantons. Source: FTA / FDF, TRAF implementation 2020-2022. |
Factual record
2 Confirmed | 1 Partly confirmed | 0 Partly refuted | 1 Refuted |
| ✓ | End of special statuses, a controlled transition The privileged tax regimes disappeared on 1 January 2020. The cantons adjusted their ordinary rates and Switzerland retained its attractiveness, with no mass corporate exodus. Source: FTA / FDF, 2020. |
| ✓ | The AHV strengthened The social component brought the AHV around 2 billion francs a year from 2020 — a real, if transitory, boost ahead of the structural AHV 21 reform. Source: FSIO, AHV accounts 2020-2021. |
| ~ | New niches, then the OECD step The reform replaced the old statuses with new instruments (patent box, R&D). The OECD minimum tax of 15%, accepted in 2023 and in force from 2024, subsequently redrew part of the tax landscape. Source: FTA; OECD, 2023-2024. |
Accepted by two thirds of voters and by all the cantons, TRAF succeeded where Corporate Tax Reform III had failed two years earlier: getting the abolition of special tax statuses accepted. The recipe? A deliberate coupling with substantial AHV financing, which won over part of the left.
Tested against the facts, the yes camp's promises held: the special statuses disappeared without economic debacle, and the AHV did receive its 2 billion a year. The appeals against the coupling were, moreover, all dismissed.
The opponents were not wrong on one point: the reform did indeed introduce new preferential instruments. But the tax story did not end there: the OECD minimum tax, adopted in 2023, has since reshuffled part of the pack — a reminder that international tax competition largely dictates the Swiss tempo.