zsis) - Center for Swiss and International Tax Law

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.