The articles of the zsis) - Center for Swiss and International Tax Law are summarized in quarterly issues at the end of each quarter. Register for free and read the current quarterly issue.
The articles of the zsis) - Center for Swiss and International Tax Law are summarized in quarterly issues at the end of each quarter. Register free of charge and read the current quarterly issue including the main topics.
You can find all quarterly issues from 2019 onwards in our archive.
zsis - Center for Swiss and International Tax Law is a digital information and research platform for practitioners. Our articles are divided into nine tax law topics and marked with corresponding colors. These contributions appear in the following formats: Articles, News and Documents.
In the following you will find a selection of the latest articles...
This issue is entirely dedicated to the topic of "Real Estate". The four articles shed light on the key issues that shape practice today. Real estate forms its own universe in tax law: the issues are complex and cantonal in nature. Between current taxation, property gains, corporate law structures and international interdependence, it is clear that even supposedly classic issues raise new questions. The latest developments impressively demonstrate how dynamic real estate taxation has become.
The Swiss real estate market is an increasingly interesting investment target for foreign investors. This article provides an introduction to the key tax aspects in connection with real estate transactions with cross-border implications. In addition to a brief outline of current tax issues, the article deals in depth with investments in commercial real estate and the question of whether an operating company or a real estate company exists for basic tax purposes, as well as the tax treatment of a sale of shares in a Swiss real estate company under Swiss unilateral law and treaty law.
This article compares the tax consequences of holding properties directly as private assets with indirect ownership via a real estate company. It explains the main differences in current taxation - under current law and after the system change that is expected to take effect from 2028 - and in the sale of properties and illustrates these using examples.
With the new publication of FTA VAT Info 11 Reporting procedure in February 2025, the scope of application of the reporting procedure was redefined and defined more precisely, particularly for real estate, through changes in practice and practical clarifications. These changes accentuate the need to examine the alternatives available for each real estate transaction in detail in order to avoid irreparable errors and minimize VAT as a cost factor.
The term "commercial real estate trader" in real estate gains tax law is based on the same term used in case law and practice for income tax purposes. The only special feature is that this term must also be applied mutatis mutandis to legal entities in the case of real estate gains tax. The fiscal signs for property gains tax are reversed: while a trader qualification for income tax purposes leads to a massive tax and social security contribution burden, the same qualification for property gains tax purposes only grants tax relief. Unsurprisingly, the same concept has developed in different directions. This article deals with the latest developments, the extent to which they differ in both areas of law and what a publication on the practice can achieve.
In the case of real estate companies, there is an incentive to shift as much profit as possible away from the tax object "real estate profit" and into the sphere of profit tax. Instead of the purchase of the property, the development of the building and the subsequent marketing being handled by a single company, the functions are split between different companies in a group of companies. This article highlights the associated problems of profit shifting and possible solutions.
In its ruling of November 26, 2024, the Tax Appeals Court of the Canton of Zurich confirmed that a taxpayer can terminate his self-employment and thus claim liquidation gains taxation even if he buys a property from the previous business assets, has it renovated together with another property acquired from his brother and rents it out, as the activity associated with the two acquired properties is not a continuation of self-employment but serves as a private investment.
It is not uncommon for privately held groups to have partnerships and other personal legal entities such as trusts, foundations or private individuals linked by shareholders' agreements at the top of the structure. This article analyzes how such legal entities are to be treated for Swiss and international supplementary taxes and to what extent the provisions of Swiss income and profit tax law have an influence on this.
The tax deduction within the scope of the tied pension provision (pillar 3a) remains unchanged for the 2026 tax year. The maximum deductions are also the relevant payment limits.
According to the notification dated November 17, 2025 FTA has revised form no. 764 for the application of the notification procedure (Art. 38 VAT Act).
At its meeting on November 5, 2025, the Federal Council adopted the dispatch on the DTA with Zimbabwe.
On October 29, 2025, the Federal Council published the report "New regulation of VAT in the area of healthcare: simplification, competitive neutrality and relief for consumers" in fulfillment of postulate 23.3132 Noser of March 14, 2023.
The State Secretariat for International Financial Matters SIF announced on October 16, 2025 that the competent authorities of Switzerland and Germany have agreed to extend the consultation agreement on the application of Article 15 paragraph 4 of the double taxation agreement between Switzerland and Germany.
On October 24, 2025, the FTA published two drafts on VAT practice on its website.
The Protocol of Amendment to the Agreement on the Automatic Exchange of Financial Account Information to Promote Tax Compliance in International Matters, signed on October 20, 2025, adapts the agreement to the amended OECD standard and supplements it with new provisions on administrative assistance in the collection of VAT claims. The consultation will last until February 6, 2026.
At its meeting on September 19, 2025, the Federal Council adopted the report in fulfillment of postulate 23.3262 Silberschmidt of March 16, 2023 "Making the emissions tax more startup-friendly".
At its meeting on September 12, 2025, the Federal Council adopted the dispatch on the approval of the international legal basis for the exchange of information for OECD minimum taxation.
The Federal Department of Finance (FDF) adjusts the rates and deductions for direct federal tax annually to offset the effects of cold progression. The latest changes concern the 2026 tax year.
On September 11, 2025, the Federal Tax Administration (FTA) published the new refund and default interest rates for federal taxes from 2026.
On September 8, 2025, the FTA announced that the VAT settlement modalities can now be adjusted directly in the "VAT settlement" online service.
In its communication dated September 1, 2025, the FTA points out that deadline extensions for VAT returns can only be requested via the "VAT return" ePortal service.
The Federal Council and Parliament recommend that the creation of a constitutional basis for cantonal property taxes on second homes be adopted on September 28, 2025. The bill is the prerequisite for a comprehensive reform of residential property taxation in Switzerland, which also aims to abolish the imputed rental value.
