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.
Federal Council opens consultation on ordinance on minimum taxation of large corporate groups
On August 17, the Federal Council opened the consultation on the Ordinance on the Minimum Taxation of Large Corporate Groups (Minimum Taxation Ordinance, MindStV).
Date for referendum on the revision of the Withholding Tax Act
The Federal Council has set the date for the referendum on the amendment of 17 December 2021 to the Federal Act on Withholding Tax (Withholding Tax Act, ITA) (strengthening the debt capital market) for 25 September.
Maritime shipping companies should be able to be taxed on the basis of tonnage
On 4 May 2022, the Federal Council adopted the dispatch on the Federal Tonnage Tax Act.
Withholding tax: Changes to the reporting procedure in the group
At its meeting on 4 May 2022, the Federal Council approved the amendments, which will enter into force on 1 January 2023.
FTA publishes tax folder Tax relief for newly opened companies of legal entities
On 21 April 2022, the FTA published a new tax folder on the topic of "Tax relief for newly opened companies of legal entities".
Adjustment of the private share in the car costs in the leaflets N1/2007 and NL1/2007
On 22 March 2022, the FTA amended the information sheets N1/2007 and NL1/2007, as Art. 5a para. 2 of the Federal Ordinance on Professional Costs came into force on 01 January 2022, which now provides for a higher flat-rate travel cost deduction of 0.9% of the purchase price of the vehicle as monthly income.
Federal Council opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Intellectual property rights
Workshop by Nathanael Zahnd and Balthasar Denger on the occasion of the ISIS) seminar on February 05, 2025 entitled "Intellectual property rights"
Financing
Workshop by Stefan Oesterhelt and Thomas Hug on the occasion of the ISIS) seminar on February 05, 2025 with the title "Financing"
Tax challenges for commercial real estate
Workshop by Robert Desax on the occasion of the ISIS) seminar on November 12, 2024 entitled "Tax challenges for commercial real estate"
ISIS) seminar folder "Withholding tax practice and outlook on current developments (2024)"
All documents from the ISIS) seminar "Withholding tax practice and outlook on current developments" held on October 21, 2024 under the direction of Thomas Jaussi 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.
