Inheritance and gift tax at federal level - the so-called "Future Initiative" of the JUSO
The "Future Initiative" aims to tax the assets of natural persons through an additional inheritance and gift tax at federal level. With an exemption amount of CHF 50 million, the tax affects wealthy individuals. The proposed tax rate was set at 50%, without providing for exceptions to taxation. Due to the existing inheritance and gift taxes, this could lead to a much higher effective tax burden. Numerous unresolved questions and a planned retroactive effect are already causing great uncertainty well before a referendum at the beginning of 2026. This article uses examples to illustrate possible consequences and measures for action.
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.
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.
Zurich shows more flexibility for start-ups
On 5 November 2019, the Finance Directorate and the Economic Directorate of the Canton of Zurich published a joint press release stating that there should be no tax obstacles to an agreed change in the ownership structure of founding shareholders.
Successful involvement of founders and employees
Workshop by Stefan Oesterhelt and Susanne Schreiber on the occasion of the ISIS) seminar on June 7, 2023, entitled "Successfully engaging founders and employees".
Tax aspects of the establishment and development of the start-up
Workshop by Rebecca Schwarzenbach and Patrick Scherrer on the occasion of the ISIS)-Seminar on June 7, 2023, entitled "Tax aspects of founding and building a start-up".
Seminar folder ISIS)-Seminar "Criminal Tax Law" (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 "Tax Criminal Law" from 09 May 2023 under the direction of Rolf Benz.
