Income tax-free repayment of a hidden capital contribution to the shareholder
The Federal Supreme Court had to decide for the first time whether the repayment of a hidden capital contribution to the shareholder constitutes taxable investment income or whether it can be made tax-free. After interpreting the term "repayment of contributions" in Art. 20 para. 3 DBG, it comes to the conclusion that hidden capital contributions also fall under this, that the accounting requirement from Art. 5 para. 1bis VStG is not relevant and that the repayment of a hidden capital contribution is income tax-free.
Algorithmically verified tax return in the ordinary mixed assessment procedure
The digitization of the tax area and, in particular, the automation of the assessment process are advancing. In the process, risk management systems can be used to automatically check the plausibility of tax returns. Such a risk analysis can lead to challenges under fundamental rights and data protection law, which must be countered in particular by creating specific legal foundations.
How mobile working is changing tax and social security law
The home office has long since become a normal form of work. It enables greater flexibility and thus a better life-work balance, which is why many employees no longer want to do without it. In addition, the home office can also be advantageous for companies: In particular, office space can be reduced, thereby saving on rental costs and energy costs, and employee motivation can be kept high.
Home office and the cross-border commuter agreement with Italy
Today, around 85,000 Italian residents work in the border cantons of Ticino, Grisons and Valais. The cross-border commuter agreement concluded with Italy is of great importance especially for the canton of Ticino with its approximately 75,000 cross-border commuters, of which around 66,000 are considered cross-border commuters within the meaning of the agreement.
Stop the tax penalty in pillar 3b. Tax the income share instead of the capital contribution in the case of a capital withdrawal
On 10 September 2018, the Council of States adopted the motion "Stop the tax penalty in pillar 3b. In the case of a capital withdrawal, tax the share of income instead of the capital contribution" with the following amendment: "The Federal Council is instructed to submit to parliament an amendment to the Federal Tax Act (DBG) and the Tax Harmonisation Act (StHG) in order to achieve a flexibilisation of the flat-rate share of income on all benefits (periodic benefits, surrender, refund) from life annuities and life insurance policies, adapted to the respective investment conditions.
WAK-S has defined key points for the system change in the taxation of residential property
After detailed discussion and extensive clarifications, the WAK-S decided how the system change in imputed rental value should be implemented and commissioned the administration and secretariat to prepare a preliminary draft.
Circular Letter Taxation according to expenditure in direct federal tax
The Swiss Federal Tax Administration has published the circular "Taxation according to expense in direct federal tax".
Taxation of residential property - advice to the WAK-S on system change in the taxation of residential property
The Commission for Economic Affairs and Taxes of the Council of States (WAK-S) has continued its deliberations on the change of system for the taxation of residential property.
Individual taxation/couple and family taxation
The marriage penalty affects considerably more two-earner couples than the Federal Tax Administration has so far quantified. So far, two-earner couples with children have not been taken into account.
Taxation of residential property - WAK-S continues consulting
The Commission for Economic Affairs and Taxes of the Council of States (WAK-S) has continued its deliberations on the change of system for the taxation of residential property.
Tax and tax law aspects relating to the exit
Workshop by Michael Barrot, Kerem Altay and Fabian Utzinger on the occasion of the ISIS) seminar on May 27, 2024 entitled "Tax and tax law aspects of exits"
Dossier de séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" (2023)
Etudes de cas, solutions détaillées et transparents : vous trouverez ici tous les documents des différents ateliers selon la description du contenu ci-dessous du séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" du 7 novembre 2023 sous la direction de Laila Rochat.
