zsis) - Center for Swiss and International Tax Law

Tax treatment of refurbishment grants in private assets

In the area of capital contributions, two landmark Federal Supreme Court rulings were issued last year. In a first ruling, the Federal Supreme Court also applied an income tax-free repayment within the meaning of Art. 20 para. 3 DBG with regard to hidden capital contributions. In a second ruling last year, the Federal Supreme Court protected the practice of the FTA, according to which the accounting offsetting of a contribution against the loss carryforwards is mandatory in order to claim the restructuring allowance pursuant to Art. 6 para. 1 lit. k StG.

Editorial on the focus "Refurbishments"

In difficult economic times, many companies are faced with considerable financial challenges. The Covid-19 pandemic in particular has led to a number of companies needing to be restructured despite the aid granted, such as loans or hardship compensation. Restructuring a company is a complex process that requires not only strategic and operational measures, but also careful consideration of legal and tax aspects. After all, restructuring a company can lead to significant tax consequences.

The valuation of participation rights in start-up companies and the principle of equal treatment

The tax valuation of start-ups has been the subject of debate in Switzerland. While a viable solution has been found for the shareholders of start-ups with the current solution, the question of an even wealth tax burden for shareholders in a comparable situation arises. Find out what challenges arise in the valuation of participation rights and what solutions are being discussed to ensure a balanced tax policy.

Questions of justice regarding the Swiss inheritance tax according to John Rawls

Is Swiss inheritance tax law fair? The author of this article examines the answer to this question by applying the philosopher John Rawls' theory of justice. It examines the fundamental question of the justification of an inheritance tax as such and the subsequent question of the design of an inheritance tax from the point of view of justice.