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.
FDK rejects popular initiative "Relieve wages, tax capital fairly
On 2 June 2020, the Conference of Cantonal Finance Directors (FDK) published a press release on the popular initiative "Relieve the burden on wages, tax capital fairly".
Consultation agreement with Germany on the taxation of railway staff
On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
ESTV - Taxation of compensation for loss of earnings due to corona
On 6 April 2020, the Swiss Federal Tax Administration published the Circular on the tax treatment of benefits under the Ordinance on Measures for Loss of Earnings in Connection with the Coronavirus.
Federal Council wants to align taxation of life annuities with interest rates
On 4 April 2020, the Federal Council adopted a consultation draft that aims to adjust the taxation of life annuities.
Selected parliamentary business in the tax area at federal level (March 2020)
The Federal Tax Administration (FTA) has published a revised version of the overview of selected parliamentary business in the tax field at federal level.
Federal Council has adopted a dispatch on the popular initiative "Relieve the burden on wages, tax capital fairly
At its meeting on 6 March 2020, the Federal Council adopted the dispatch on the popular initiative "Relieve the burden on wages, tax capital fairly" (unofficially "99% initiative"). The Federal Council recommends that the initiative be rejected without a counterproposal.
Tax-deductible interest rates 2020 for advances or loans in Swiss francs and foreign currencies
The granting of interest-free or insufficiently interest-bearing advances or loans to participants or third parties related to them constitutes a payment in kind. This shall also apply to translated interest which is paid on the basis of obligations to participants or third parties close to them.
Home office before and after the pandemic (intercantonal and international situations)
Workshop by Ueli Zehnder and Jennifer Herren on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
Practical questions due to the withholding tax revision from the employee's point of view
Workshop by Patrick Meier and Dirk Hangarter on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
Tax challenges of partnerships
Workshop by Julia von Ah and Toni Hess on the occasion of the ISIS) seminar on 14/15 and 21/22 June 2021 entitled "Corporate Tax Law 2021".
ISIS) seminar "Advance withdrawal, inheritance, division of an estate and execution of a will in tax law" (seminar folder)
Case studies, detailed solutions and slides: Here you will find all the documents (workshops and presentations) according to the following description from the ISIS seminar "Erbvorbezug, Erbgang, Erbteilung und Willensvollstreckung im Steuerrecht" (Advance withdrawal, inheritance, division of an estate and execution of a will in tax law) of 26 November 2020, which was held at the Marriott Hotel in Zurich under the direction of Peter Mäusli-Allenspach.
