Emission tax for refurbishments
A distressed company can be restructured in various ways. Balance sheet restructuring measures that do not provide the company with any external funds are not subject to the issue tax. Financial restructuring measures, on the other hand, are subject to the issuance stamp duty of one percent if they are carried out in return for the issue of participation rights or if shareholders make a contribution.
Editorial on the focus "Refurbishments"
In difficult economic times, many companies are faced with considerable financial challenges. The Covid-19 pandemic in particular has led to a number of companies needing to be restructured despite the aid granted, such as loans or hardship compensation. Restructuring a company is a complex process that requires not only strategic and operational measures, but also careful consideration of legal and tax aspects. After all, restructuring a company can lead to significant tax consequences.
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.
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.
Publication reference: Message and draft on the amendment of the Withholding Tax Act (too-big-to-fail instruments)
At its meeting on June 6, 2025, the Federal Council approved the dispatch and draft amendment to the Withholding Tax Act (too-big-to-fail instruments).
Income and withholding tax: Determination of the maximum permissible conversion discount
On April 22, 2025, the FTA published notice 024-DVS-2025 regarding the determination of the maximum permissible conversion discount.
Supplementary tax: Tax treatment of business units that qualify as permanent establishments
On March 18, 2025, the FTA explained the treatment of business units that are considered permanent establishments in a communication on the minimum taxation of multinational enterprise groups.
FTA publishes circular no. 32a: Reorganization of corporations and cooperatives
On January 20, 2025, the FTA published circular no. 32a regarding the "Restructuring of corporations and cooperatives".
FTA publishes imputed interest rate on the security equity 2025
The imputed interest rate on the security equity corresponds to the yield on ten-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period in accordance with Article 25abis paragraph 4 first sentence StHG.
Federal Council adopts dispatch on the extension of loss offsetting
On November 27, 2024, the Federal Council adopted the dispatch on extending loss offsetting from seven to ten years.
Practical specifications for sales tax for brokerage activities within a group relationship
Recent case law in the area of sales tax for intermediaries in a group relationship has prompted the FTA to make clarifications in its administrative practice regarding Art. 13 para. 1 and Art. 13 para. 3 lit. b no. 2 StG. The two practical clarifications will be applied with immediate effect and will apply to all cases currently pending with the FTA.
News on the taxation of corporate restructuring (2025)
Workshop by Stefan Oesterhelt and Daniel Strahm on the occasion of the ISIS seminar on 2 and 3 June 2025 entitled "Current issues regarding the taxation of corporate restructurings"
Update on withholding tax and stamp duties (2025)
Workshop by Thomas Jaussi and Markus Küpfer on the occasion of the ISIS) seminar on June 02 + 03, 2025 entitled "Update on withholding tax and stamp duties"
