Intercantonal change of residence of persons subject to withholding tax, which are subsequently assessed in an orderly manner
In the case of an intercantonal change of residence of persons subject to withholding tax who are subsequently assessed in an orderly manner, the question arises as to which canton or cantons have the right to tax the earned income and other income and taxable assets. In BGE 140 II 167, the Federal Supreme Court answered this question with regard to persons subject to the FMPA who transfer their residence to a canton with lower taxation. After outlining the legal basis and discussing the above-mentioned Federal Supreme Court ruling, the author examines the question of how persons not subject to the FMPA are treated and what the (tax) consequences are if - in the opposite case - a natural person moves to a canton with a higher tax rate and is resident there at the end of the tax year.
ISIS seminar folder "Gratuitous transfer of assets under tax law"
All documents from the ISIS) seminar "Gratuitous transfer of assets in tax law" from October 28, 2025 under the direction of Peter Mäusli-Allenspach 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.
Practical examples of cross-border issues in relation to Germany
Case studies, slides and detailed solution notes from the workshop held by Hanna Brozzo and Iring Christopeit on October 28, 2025 on the occasion of the ISIS seminar "Gratuitous asset transfers in tax law".
