When does the tax authority treat easements as transactions that are equivalent to a sale of real estate?
The article analyzes the tax treatment of compensation paid in connection with the encumbrance by easements or their deletion. The focus is on the question of whether such transactions are equivalent to a sale and are subject to property gains tax. Legal criteria and practical examples are used to show how these cases are assessed under tax law.
Invalidity of discretionary assessments
With its latest decision of August 19, 2024 (9C_673/2023), published on September 25, 2024, the Federal Supreme Court confirms and clarifies its practice on the nullity of discretionary assessments.
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.
.jpg)
.jpg)
Canton of Zurich - Adjustment of the information sheet on the granting of social deductions and the application of tax rates for families
The canton of Zurich has adapted the information sheet (ZStB No. 34.2) to the new legal calculation.
Mutual agreement between Switzerland and the USA on withholding tax exemption for pension plans
The Protocol of Amendment to the Double Taxation Treaty between Switzerland and the USA, which was approved on 17 July 2019, provides that dividends paid to tied pension institutions (e.g. pillar 3a) will be exempt from withholding tax from 1 January 2020, provided that they do not control the US company paying the dividends.
Canton of Zurich - Adjustment of the fact sheets on the deduction of property maintenance costs and energy-saving measures and updating of the Zurich tax booklet
Since the 2020 tax period, there is the new deductibility of deconstruction costs with regard to a replacement new building (section 30 para. 2 StG) and the transferability of expenses for investments that serve to save energy and protect the environment, as well as deconstruction costs with regard to a replacement new building (section 30 para. 2bis StG). These costs are deductible in the two subsequent tax periods insofar as they could not be fully taken into account for tax purposes in the current tax period. The two information sheets were adapted for this purpose:
Notice from the Cantonal Tax Office Zurich regarding professional expenses and Corona in the 2021 tax period
On 26.03.2021, the Cantonal Tax Office of Zurich published a notice according to which dependent employees can claim their professional expenses for the year 2021, as they did for the year 2020, as if there had been no measures to combat the Corona pandemic.
FTA extends flat-rate taxation for the private use of business vehicles
On 17 March 2021, the FTA published the amendment to Art. 5a of the Professional Costs Ordinance. On the one hand, the current flat rate will be regulated in the Professional Costs Ordinance from 1 January 2022, and on the other hand, the flat rate will now take into account commuting costs and will be increased from 0.8% to 0.9% per month (or from 9.6% to 10.8% per year) for this purpose.
Taxation of capital benefits in the Canton of Zurich
The taxation of lump-sum benefits on withdrawals from the pension fund or the third pillar will be reduced in the canton of Zurich from the beginning of 2022 in order to take account of higher life expectancy and lower conversion rates in occupational pension provision.
.jpg)
Investments in crypto assets
Workshop by Silvan Guler and Daniel Bürki on the occasion of the ISIS) seminar on September 23-24, 2024 entitled "Investments in crypto assets"
Current problems of taxation of stock corporations and shareholders (2024)
Workshop by Oliver Jäggi and Benno Eberhard on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current problems of taxation of stock corporations and shareholders"
ISIS) seminar folder "Startups - tax and duty law challenges: Refinancing and Exit" (2024)"
All documents from the ISIS) seminar "Startups - Tax and Duty Law Challenges: Refinancing and Exit" from May 27, 2024 under the direction of Ruth Bloch-Riemer in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
