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.
FTA - Notification withholding tax: Declaration of reserves from capital contributions
On September 18, 2024, the FTA clarified the administrative practice in accordance with item 9 of circular no. 29c on the capital contribution principle dated December 23, 2023 regarding the declaration of reserves from capital contributions.
International supplementary tax IIR to come into force in 2025
At its meeting on September 4, 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force on January 1, 2025. In addition to the QDMTT, which was already introduced on January 1, 2024, this rule is intended to ensure that tax revenue remains in Switzerland.
Transitional solution for the too-big-to-fail instruments for withholding tax
At its meeting on August 21, 2024, the Federal Council approved a temporary extension of the special regulations for interest from TBTF instruments until December 31, 2031. Without an additional extension, interest on TBTF instruments issued after December 31, 2026 would be subject to withholding tax.
Introduction of the OECD/G20 minimum taxation on January 1, 2024
On December 22, 2023, the Federal Council decided to levy the supplementary tax in Switzerland from January 1, 2024.
FTA publishes tax statistics of natural and legal persons 2020
On 16 November 2023, the FTA published the 2020 tax statistics.
FDF publishes first report on cantonal measures in connection with the implementation of the OECD minimum tax
On August 8, 2023, the FDF published the first report on the expected impact of the implementation of the OECD minimum tax on the individual cantons as well as the planned measures of the individual cantons as of May 31, 2023.
Federal Council opens consultation on expanded loss offsetting
According to parliament, the loss offset period for companies is to be extended from seven to ten years. This is intended to enable companies affected by the Corona pandemic in particular to recover better. The Federal Council has drawn up the legal amendments for this and opened the consultation process at its meeting on June 28, 2023.
ISIS) seminar folder "Exchange of services between affiliated companies (2025)"
All documents from the ISIS) seminar "Exchange of services between affiliated companies" from February 05, 2025 under the direction of Thomas Hug 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.
Transfer pricing for SMEs
Workshop by Stefan Piller and Rita Sommariva on the occasion of the ISIS) seminar on February 05, 2025 entitled "Transfer Pricing for SMEs"
