Clarification of Notice-024-DVS-2025-d of 22.04.2025 - Income and withholding tax: Determination of the maximum permissible conversion discount

On May 19, 2025, the FTA specified the future practice in Communication 024-DVS-2025 regarding the determination of the maximum permissible conversion discount.

The following applies: If the value of the relevant participation right is not known at the time the convertible bond is issued or the convertible loan is granted, the market value at the time the conversion right is exercised shall be decisive. The maximum permissible conversion discount remains at 33 1/3%.

The clarification of the communication is available here.

Our first article from April 26, 2025 on this communication is available here.