§ 67 Tax Act (StG) - Tax Allocation

1. Tax Apportionment is carried out in relation to other cantons according to the principles of federal law concerning the prohibition of intercantonal double taxation, and in relation to foreign countries according to international treaties to avoid double taxation.

2. Losses from foreign real estate can only be taken into account if there is also a permanent establishment maintained in the respective country. A Swiss company can offset losses from a foreign permanent establishment against domestic profits, provided these losses have not yet been considered in the state where the permanent establishment is located. If this permanent establishment records profits within the following seven fiscal years, taxation will occur in these fiscal years to the extent of the loss carryforwards offset in the permanent establishment state. Otherwise, foreign losses are only to be considered in the cases prescribed by double taxation agreements.

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