Succession planning: tax pitfalls
When Swiss families think about the organization of their estate, they generally do not pursue any immediate tax objectives. In general, it is more a question of transferring assets to the next generation or at least initiating the future reorganization of ownership structures in the present. Of course, reducing wealth tax and breaking the tax progression, for example, can be an accompanying motive, but practice shows that this is rarely the actual "trigger". This article presents some typical questions.
The tax treatment of (underpriced) non-family business succession with special consideration of Ticino practice
Does an underpriced transfer of shares to an employee always lead to income tax consequences? With this article, the authors want to stimulate discussion on a very relevant aspect of non-family business succession: the distinction between (income taxable) employee shareholdings and (possibly non-income taxable) succession arrangements. The authors take a look at the practice and case law in the canton of Ticino and other cantons as well as the possible effects of recent inheritance law reforms.
Tax aspects of family business succession
In the coming years, many small and medium-sized companies will face the challenge of arranging their succession. A transfer against payment or free of charge may be considered in order to remain in family ownership. The planning and implementation of succession is an important topic for entrepreneurs with links to numerous areas of law. This article is dedicated to the tax challenges and solution strategies in family business succession in order to support companies in strategically well thought-out and tax-optimized planning.
Taxation of spouses in international relations - tax segregation issues
In the zsis) issue of November 2019, the authors dealt with tax law stumbling blocks in the taxation of spouses in international relationships. In this article, they have focused on the tax segregation of international spouses. On the basis of a test scheme with three questions, they show that a systematic procedure is essential for correct tax segregation and that there is still a need for action here on the part of the assessment authority and the courts.
FTA - Life annuities will be taxed flexibly as of 2025
The taxation of life annuities in pillar 3b will be flexibly adjusted to the investment conditions when it comes into force on January 1, 2025.
Consultation agreement between Switzerland and Germany concerning withholding taxes
The State Secretariat for International Financial Matters SIF announces that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the procedure for relief from German withholding taxes on dividends, interest and royalties under the double taxation agreement between Switzerland and Germany.
Federal Council opens consultation for new regulation of professional costs
At its meeting on December 21, 2022, the Federal Council opened the consultation process for a new regulation of professional costs.
Maximum Pillar 3a deductions in tax year 2023
The tax deduction under the tied pension plan (pillar 3a) was adjusted for the tax year 2023 and amounts to:
FTA publishes tax statistics for individuals and legal entities 2019
On November 3, 2022, the FTA published the 2019 tax statistics.
FTA publishes interest rates for direct federal tax 2023
On October 13, 2022, the Federal Tax Administration (FTA) published the - unchanged - interest rates for the 2023 direct federal tax:
Tax justice initiative has come to fruition
The federal popular initiative "For individual taxation independent of civil status (tax justice initiative)" submitted on September 8, 2022, has formally come into effect.
FTA - Circular on professional expense allowances and remuneration in kind 2023 / Compensation for the consequences of the cold progression in direct federal tax for the tax year 2023
On September 21, 2022, the FTA published the circular "Professional expenses lump sums and remuneration in kind 2023 / Compensation of the consequences of the cold progression in the direct federal tax for the tax year 2023".
Family foundations and trusts in estate planning
Workshop on "Family Foundations and Trusts in Estate Planning" by Daniel Bader, Hanna Brozzo and Marlene Kobierski on the occasion of the ISIS seminar "Structuring Private Wealth by Means of Trusts or Foundations" on October 31, 2023.
ISIS)-Seminar folder "Taxation of shareholder and company in personal companies" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Taxation of Shareholder and Company at Personally Owned Businesses" from September 18 - 19, 2023 under the direction of Andrea Opel.
Reclassification of capital gain as taxable capital income
Workshop on "Reclassification of capital gain from sale into taxable capital gain" by Thomas Wolfensberger and Marco Buchmann on the occasion of the ISIS seminar "Taxation of Shareholder and Company in Personally Owned Businesses" on September 18 - 19, 2023.