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.
Federal Council supports abolition of imputed rental value
The Federal Council proposes that Parliament accept the bill of the Committee for Economic Affairs and Taxation of the Council of States (WAK-S), which proposes a change in the system of residential property taxation. At the same time, it proposes amendments to key parameters.
WAK of the National Council narrowly approves parliamentary initiative 21.424 "Deduct maintenance contributions also for over 18-year-olds
In its press release of 18 August 2021, the WAK of the National Council informed about the narrow approval of the parliamentary initiative 21.424 "Deduct maintenance contributions also for over 18-year-olds".
Application of the most-favoured-nation clause according to the protocol of the double taxation agreement between Switzerland and India
In its communication of 13 August 2021, the State Secretariat for International Financial Matters (SIF) provides information on the changes to dividend taxation due to the application of the most-favoured-nation clause in the DTA CH-IN.
FTA publishes circular concerning professional expense allowances and remuneration in kind 2022
On 13 August 2021, the Federal Tax Administration (FTA) published the circular "Professional expenses lump sums and remuneration in kind 2022 / Compensation for the consequences of the cold progression in direct federal tax for the tax year 2022".
Federal Council adopts dispatch on new cross-border commuter agreement with Italy
At its meeting on 11 August 2021, the Federal Council adopted the dispatch on the new cross-border commuter agreement between Switzerland and Italy.
FDF - The reporting procedure for natural persons will not be pursued further
Based on the findings of a working group, the FDF decided on 5 August 2021 not to pursue the idea of a new reporting procedure for natural persons for withholding tax.
Specialties in wealth tax (valuation, bouclier fiscal, etc.)
Workshop by Marco Greter and Nina Blanz on the occasion of the ISIS) seminar on September 23-24, 2024 entitled "Specialties in wealth tax"
Asset structuring through trusts and foundations
Workshop by Andrea Opel and Andrea Hildebrand on the occasion of the ISIS seminar from 23 - 24 September 2024 entitled "Asset structuring using trusts and foundations"