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.
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Greater fiscal consideration of the costs of third party childcare
The Economic Commission of the National Council has accepted without opposition the Federal Council's Dispatch 18.050 concerning the tax recognition of third-party childcare costs. This proposal is related to the initiative for skilled workers and is intended to promote the employment of women. The Commission considers that taxing the cost of external care can be an argument for women wishing to enter the labour market, as the cost of care is too high for many young families. In the overall vote, the Commission approved the unchanged proposal by 11 votes to 8 with 5 abstentions. However, a minority of the Commission wishes to limit the deduction to the proven costs of institutional provision of childcare outside the family (rejected by 18 votes to 5), while a second minority demands a deduction not only for third-party but also for self-care of children (rejected by 13 votes to 10). The transaction is expected to be dealt with in the spring session 2019.
Marriage penalty: External expert recommends a broader data basis for the FTA
The statistical basis for direct federal tax, on which the Federal Tax Administration (FTA) can draw, is insufficient. Therefore, especially the estimation of the number of persons affected by the marriage penalty remains subject to uncertainty. This is the conclusion of an external report commissioned by the Federal Department of Finance (FDF), the results of which were presented to the Federal Council at its meeting on 7 November 2018.
Remuneration interest rate for direct federal tax remains the same
The Federal Department of Finance (FDF) has decided to continue not to pay any refund interest for the calendar year 2019 on amounts of direct federal tax paid early.
National Council maintains mandate for tax deductions
The National Council insists that the Federal Council implement an adopted motion on the taxation of foreigners. On 27 September 2018 he refused to write them off.
Harmonisation of interest rates for federal tax exemptions
On 10 September 2018, the Council of States adopted the motion "Harmonisation of interest rates in federal tax decrees" with the following amendment: "The Federal Council is instructed to harmonise interest rates in federal tax decrees in such a way that a generally applicable default and refund interest rate is established".
Stop the tax penalty in pillar 3b. Tax the income share instead of the capital contribution in the case of a capital withdrawal
On 10 September 2018, the Council of States adopted the motion "Stop the tax penalty in pillar 3b. In the case of a capital withdrawal, tax the share of income instead of the capital contribution" with the following amendment: "The Federal Council is instructed to submit to parliament an amendment to the Federal Tax Act (DBG) and the Tax Harmonisation Act (StHG) in order to achieve a flexibilisation of the flat-rate share of income on all benefits (periodic benefits, surrender, refund) from life annuities and life insurance policies, adapted to the respective investment conditions.
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.
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Intra-family succession and management succession
Workshop by Julia von Ah and Thomas Gammeter on the occasion of the ISIS) seminar on May 27, 2024 entitled "Family succession and succession in the context of management"
Tax and tax law aspects relating to the exit
Workshop by Michael Barrot, Kerem Altay and Fabian Utzinger on the occasion of the ISIS) seminar on May 27, 2024 entitled "Tax and tax law aspects of exits"
Dossier de séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" (2023)
Etudes de cas, solutions détaillées et transparents : vous trouverez ici tous les documents des différents ateliers selon la description du contenu ci-dessous du séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" du 7 novembre 2023 sous la direction de Laila Rochat.
