02/2022
Circular No. 5a Restructuring
Natalya Ezzaini
The new circular no. 5a on tax-neutral reorganisations was published on 1 February 2022. The following key adjustments were made in the circular:
The consequences for the capital contribution reserves for the individual restructuring facts were explained.
- A participation rate of 10% is required for tax-neutral spin-offs and replacements (instead of 20%).
- Holding split
- Partially tax-neutral restructuring
- The levying of the issue duty in the event of a blocking period violation is not applicable due to the lack of a legal basis.
The circular no. 5a is available here.
First publication:
Circular No. 5a Restructuring
www.taxlawblog.ch
Footnotes / further notes
.
.
Footnotes / further notes:
