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.
Far more than cryptocurrencies ...
The editorial for the focus issue "Blockchain, Crypto and NFTs". In recent years, blockchain technology has caused a stir around the world. In this context, tax law has dealt with blockchain technology primarily in connection with cryptocurrencies. However, the scope of blockchain technology goes far beyond cryptocurrencies.
Taxation of NFTs in the luxury industry - a case study
Non-fungible tokens ("NFTs" for short), i.e. unique cryptographic tokens representing physical or digital value, are currently on everyone's lips - at least since the NFT "Everydays: the First 5000 Days" was auctioned by Christie's in 2021 for USD 69.3 million. Using the NFTs of the watch brand DuBois et fils, which were issued for the first time in 2021, it will be shown how companies in the luxury sector can use NFTs both to market products and to build a close customer relationship, and which tax issues have to be taken into account.
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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Online refund application of withholding tax for persons resident in Germany
An online application of the Swiss Federal Tax Administration (FTA) will be available for refund applications for Swiss withholding tax by German residents from 31 January 2020.
The Swiss Federal Tax Administration has published Circular Letter No. 29b "Capital Contribution Principle
On 23 December 2019, the Swiss Federal Tax Administration published Circular Letter No. 29b "Capital Contribution Principle". Circular Letter No. 29b comes into force on 1 January 2020 and replaces the previous circular letters No. 29 and 29a.
Implementation of STAF: Regulations enter into force on 1 January 2020
At its meeting on 13 November 2019, the Federal Council approved three ordinances on the Federal Tax Reform and OASI Financing Act (STAF). These amendments concerning the tax part will enter into force on 1 January 2020.
WAK of the National Council for the abolition of the turnover tax and the insurance tax or reform of the withholding tax
In its media release of 5 November 2019, the National Council's WAK provided information on the parliamentary initiative on turnover tax and insurance tax, on the reform of withholding tax and on the neutrality of legal forms in corporate taxation.
Zurich shows more flexibility for start-ups
On 5 November 2019, the Finance Directorate and the Economic Directorate of the Canton of Zurich published a joint press release stating that there should be no tax obstacles to an agreed change in the ownership structure of founding shareholders.
FTA publishes tax statistics 2016
On 1 November 2019, the Swiss Federal Tax Administration (FTA) published the tax statistics of natural and legal persons for 2016.
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Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
ISIS) seminar "Practical cases on withholding tax and outlook on current developments" (seminar folder)
Case studies, detailed solution notes and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS) seminar "Practical cases on withholding tax and outlook on current developments" of 21.09.2020 under the direction of Thomas Jaussi, which took place in the Marriott Hotel in Zurich.
