Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
The valuation of participation rights in start-up companies and the principle of equal treatment
The tax valuation of start-ups has been the subject of debate in Switzerland. While a viable solution has been found for the shareholders of start-ups with the current solution, the question of an even wealth tax burden for shareholders in a comparable situation arises. Find out what challenges arise in the valuation of participation rights and what solutions are being discussed to ensure a balanced tax policy.
"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.
Compensation paid by Swiss companies to foreign directors
This video provides information on the possible tax and social security implications of a board of directors resident in an EU country in the case of a Swiss company limited by shares if the board of directors is also self-employed in its country of residence.
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Simultaneous dividend booking in group relationships
The Swiss Accounting and Reporting Manual allows a domestic parent company to recognize the investment income of its subsidiary (i.e. its dividend declared in financial year n+1) as income on a deferred basis in the financial year in which the subsidiary earned it. If the parent company makes the final booking of this income to the income statement at the time of distribution of the dividend, this constitutes proper booking for the purposes of the refund of the withholding tax and for the implementation of the reporting procedure.
Tax template 17 is linked to AHV restructuring
Tax Bill 17 will be linked to the AHV restructuring. This was decided by the Council of States. This approach is intended to help the corporate tax reform achieve a breakthrough and relieve the burden on old-age pensions.
Withholding tax refund despite non-declaration in the tax return - National Council vote
Anyone who has not declared income in the tax return should still receive the withholding tax back if he has been negligent. The National Council has approved this change, but wants to go considerably further than the Federal Council.
Tax submission 17 (12 April 2018)
The Committee for Economic Affairs and Taxes of the Council of States (WAK-S) has already unanimously agreed to tax bill 17 at its meeting on 12 April 2018. At its meeting on 15 May 2018, the WAK-S unanimously supported an overall concept with the following four central elements:
Deductibility of fines and penalties
In its decision of 26 September 2016, the Federal Supreme Court had to rule on a case concerning the tax law admissibility of a provision in connection with an EU cartel fine. The affected X. AG filed an appeal against the decision of the Cantonal Tax Office of Zurich with the Tax Appeal Court of the Canton of Zurich, which upheld the appeal. The cantonal tax office appealed unsuccessfully against this decision to the Administrative Court of the Canton of Zurich, which dismissed the appeal in its ruling of 9 July 2014 on both state and municipal taxes and direct federal taxes. The cantonal tax office then lodged an appeal with the Federal Supreme Court in matters of public law.
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Trust et trustees: Obligations en matière de droit de timbre de négociation / Quelques aspects d'impôt anticipé en matière de trusts et fondations
Workshop by Laïla Rochat and Emilia Rebetez on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
Questions choisies d'impôts directs, droits de donation et succession
Workshop by Nicolas Candaux and Arnaud Cywie on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
Seminar folder ISIS)-Seminar "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation" (2022)
Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation" of November 16, 2022 under the direction of Laïla Rochat.
