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.
Far more than cryptocurrencies ...
The editorial for the focus issue "Blockchain, Crypto and NFTs". In recent years, blockchain technology has caused a stir around the world. In this context, tax law has dealt with blockchain technology primarily in connection with cryptocurrencies. However, the scope of blockchain technology goes far beyond cryptocurrencies.
Switzerland and Italy agree on permanent tax rules for working from home
On 10 November 2023, Federal Councillor Karin Keller-Sutter and the Italian Minister of Finance and Economy signed a declaration that permanently regulates the issue of taxation of home office for cross-border commuters.
Federal Council in favour of including taxes in the subsistence minimum
In a report dated 1 November 2023, the Federal Council is in principle in favour of taking taxes into account when calculating the minimum subsistence level under debt enforcement law. However, the new rules on calculation are intended to ensure the payment of tax claims and to protect the claims of dependants under family law.
Maximum deductions for pillar 3a in the 2024 tax year
The tax deduction for tied self-provision (pillar 3a) remains unchanged for the 2024 tax year.
FTA - Circular on professional expense allowances and remuneration in kind 2024 / Compensation for the consequences of the cold progression in direct federal tax for the tax year 2024
On September 5, 2023, the FTA published the circular "Professional expenses lump sums and remuneration in kind 2024 / Compensation of the consequences of the cold progression in the direct federal tax for the tax year 2024".
Federal Council sets benchmarks for individual taxation
At its meeting on August 30, 2023, the Federal Council defined the key parameters for the dispatch on the introduction of individual taxation. This bill will also serve as an indirect counter-proposal to the popular initiative "For individual taxation independent of civil status (tax fairness initiative)".
Cross-border commuter agreement with Italy has entered into force
On July 19, 2023, SIF announced that the new cross-border commuter agreement with Italy and an amending protocol to the DTA entered into force on July 17, 2023. The provisions are applicable as of January 1, 2024.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
Seminar folder ISIS)-Seminar "Withholding Tax: Selected Case Constellations" (2021)
Case studies, detailed solution notes and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS) seminar "Withholding tax: Selected case constellations" of 31 August 2021 under the direction of Martin Huber, which took place in Zurich.
Quasi-residency and comparable circumstances
Workshop by Jennifer Herren, Dirk Hangarter and Patrick Meier on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
