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 publishes Circular Letters 22a and 23a concerning the partial taxation of income from investments held as private and business assets
On 31 January 2020, the Federal Tax Administration (FTA) published Circular Letters No. 22a "Partial Taxation of Income from Participations as Part of Private Assets and Restriction of Debt Interest Deduction" and No. 23a "Partial Taxation of Income from Participations as Part of Business Assets and Participations Declared as Business Assets".
Canton ZH: Changes to the flat-rate tax credit
The ordinance on the implementation of the flat-rate tax credit was adapted to the new requirements of federal law as of 1 January 2020. On the same date, the Ordinance on cantonal tariffs for calculating the maximum amount up to which a flat-rate tax credit can be granted to natural persons was repealed.
Online refund application of withholding tax for persons resident in Germany
An online application of the Swiss Federal Tax Administration (FTA) will be available for refund applications for Swiss withholding tax by German residents from 31 January 2020.
FTA publishes Circular Letter 48 "Forfeiture of the right of natural persons to a refund of withholding tax pursuant to Article 23 VStG".
On 4 December 2019, the Federal Tax Administration (FTA) published Circular Letter 48 concerning the forfeiture of the right to a refund of withholding tax from individuals.
Federal Council proposes changes to withholding tax
At its meeting on 6 December 2019, the Federal Council opened the consultation procedure on changes to the ordinance on withholding tax. Accordingly, heirs should reclaim the withholding tax on inheritance income in their canton of residence.
WAK of the Council of States occurs System change in imputed rental value
After the WAK of the Council of States had commissioned the administration at its August meeting to look into various issues in greater detail, it has now taken up the discussion of the change of system for imputed rental value and, according to the media release of 15 November 2019, voted in favour by 10 to 3 votes.
Tax law challenges for partnerships (2025)
Workshop by Susanne Schreiber and Toni Hess on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Tax law challenges of partnerships"
ISIS) seminar folder "The world of work on the move: tax and social security challenges (2025)"
All documents from the ISIS) seminar "The world of work on the move: tax and social security challenges" held on May 22, 2025 under the direction of Petra Caminada in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents from the individual workshops according to the following content description.
