Effective January1, 2022, the Canton of Vaud has modified the calculation of the tax shield, notably by re-including in the reference income the portion of dividends from qualifying holdings that benefit from partial taxation. This change significantly reduces the scope of the tax shield for shareholders holding qualifying holdings (exceeding 10% of the capital). In the face of opposition from business circles, the Grand Council reverted to the regime in effect prior to 2022, but made the entry into force of this reversal contingent on the outcome of the vote on the so-called “12%” initiative, scheduled for September 27, 2026, pursuant to a mechanism whose validity was confirmed by the Federal Supreme Court in its ruling 9C_541/2025.