"Structure follows strategy" in corporate succession - insights from the SIX Swiss Exchange Family Business Conference 2023
"Structure follows strategy" is a conclusion of the American business historian Alfred D. Chandler, which states that the strategy should be defined first and then a structure that leads to the realization of the strategy. This principle is often not sufficiently taken into account in corporate succession and the focus is prematurely placed on implementation and structuring issues. The topics discussed at this year's SIX Swiss Exchange Family Business Conference are set out below against this background.
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.
FDF adjusts tax rates and deductions to inflation
The Federal Department of Finance (FDF) adjusts the rates and deductions for direct federal tax annually to offset the effects of cold progression. The latest changes concern the 2026 tax year.
FTA publishes new refund and default interest rates for federal taxes from 2026
On September 11, 2025, the Federal Tax Administration (FTA) published the new refund and default interest rates for federal taxes from 2026.
Federal Council and Parliament recommend reform of residential property taxation for approval
The Federal Council and Parliament recommend that the creation of a constitutional basis for cantonal property taxes on second homes be adopted on September 28, 2025. The bill is the prerequisite for a comprehensive reform of residential property taxation in Switzerland, which also aims to abolish the imputed rental value.
Federal Council adopts dispatch approving the list of 74 partner states for the automatic exchange of information on crypto assets
On June 6, 2025, the Federal Council adopted the dispatch approving the introduction of the international automatic exchange of information (AEOI) on crypto assets with the relevant partner states. Entry into force is planned for 2026 with the first exchange of data in 2027.
Clarification of Notice-024-DVS-2025-d of 22.04.2025 - Income and withholding tax: Determination of the maximum permissible conversion discount
On May 19, 2025, the FTA specified the future practice in Communication 024-DVS-2025 regarding the determination of the maximum permissible conversion discount.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Taxation of board of directors and foundation board fees
Case studies and detailed solutions from Laetitia Fracheboud and Olivier Margraf. This workshop was part of the ISIS seminar "Pensions and Insurance" on September 22 and 23, 2025.
Capital withdrawals from pension plans (incl. partial withdrawals)
Case studies and detailed solutions from Stefan Oesterhelt and Sirgit Meier. The workshop was part of the ISIS seminar "Pensions and Insurance" on September 22 + 23, 2025.
Tax law challenges for partnerships (2025)
Workshop by Susanne Schreiber and Toni Hess on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Tax law challenges of partnerships"
ISIS) seminar folder "The world of work on the move: tax and social security challenges (2025)"
All documents from the ISIS) seminar "The world of work on the move: tax and social security challenges" held on May 22, 2025 under the direction of Petra Caminada in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents from the individual workshops according to the following content description.
