Restructuring merger between sister companies
This article first explains the different concepts of the need for reorganization under commercial law and tax law as well as the requirements for the tax recognition of the assumption of loss carryforwards in the context of a reorganization merger between sister companies. The tax consequences for the merged companies and for the joint shareholders are then also examined using examples.
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.
WAK-S has defined key points for the system change in the taxation of residential property
After detailed discussion and extensive clarifications, the WAK-S decided how the system change in imputed rental value should be implemented and commissioned the administration and secretariat to prepare a preliminary draft.
Circular Letter Taxation according to expenditure in direct federal tax
The Swiss Federal Tax Administration has published the circular "Taxation according to expense in direct federal tax".
Taxation of residential property - advice to the WAK-S on system change in the taxation of residential property
The Commission for Economic Affairs and Taxes of the Council of States (WAK-S) has continued its deliberations on the change of system for the taxation of residential property.
Individual taxation/couple and family taxation
The marriage penalty affects considerably more two-earner couples than the Federal Tax Administration has so far quantified. So far, two-earner couples with children have not been taken into account.
Taxation of residential property - WAK-S continues consulting
The Commission for Economic Affairs and Taxes of the Council of States (WAK-S) has continued its deliberations on the change of system for the taxation of residential property.
Intra-family succession against payment and without payment
Workshop by Alexandra Hirt on the occasion of the ISIS) seminar on November 16, 2022 entitled "Tax Aspects of Business Succession".
Questions choisies d'impôts directs, droits de donation et succession
Workshop by Nicolas Candaux and Arnaud Cywie on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
