"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.
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.
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.
Robotisation does not endanger tax revenues
Robotisation does not jeopardise tax revenues and should not be taxed specifically for the time being. This is the conclusion of the report on a prospective study, which the Federal Council approved at its meeting on 7 December 2018.
Federal Council wants to further improve framework conditions for Blockchain/DLT
At its meeting on 7 December 2018, the Federal Council adopted a report on the legal framework for block chain and distributed ledger technology (DLT) in the financial sector. The report shows that the Swiss legal framework is well suited to deal with new technologies, including block chaining. Nevertheless, there is still a need for adjustment in some areas. The Federal Council also took note of the analysis of an interdepartmental working group on money laundering and terrorist financing risks of crypto assets.
Federal practices for principal companies and Swiss Finance Branches from 1 January 2019
As part of the Tax Bill and OASI Financing (STAF), the Federal Tax Administration (FTA) will no longer apply the federal practices for principal companies and Swiss Finance Branches to companies seeking to take advantage of these practices for the first time beginning in 2019.
Reform of the withholding tax
The Economic Commission of the National Council discussed further work on the parliamentary initiative 17,494 after the sister commission of the Council of States had approved its decision to follow this initiative (cf. WAK-S press release of 20 August 2018). In this context, she discussed in particular with the head of the responsible department the Federal Council's plans for reforming the withholding tax and changing from the debtor to the paying agent principle. Subject to the approval of the Office of the National Council, the commission decided by 16 votes to 8 to set up a sub-commission and to instruct it to prepare a preliminary draft for the implementation of the parliamentary initiative. The subcommittee should coordinate its work with that of the Federal Council.
Zurich: Application for cantonal SV17 implementation submitted
The Government Council of the Canton of Zurich wants to maintain and strengthen the tax competitiveness of Zurich as a business location. To this end, it submits to the Cantonal Council a tailor-made cantonal implementation draft for the cities and municipalities that is compatible with the federal tax proposal 17 (SV17). The template is of vital importance for the entire canton. According to new model calculations, the loss of income is likely to be lower than under the Corporate Tax Reform III (USR III).
Tax bill 17 - Councils agree
The councils are in agreement on tax bill 17, and the last differences regarding the municipal article and the capital contribution principle have been resolved. An overview of the most important key points regarding tax submission 17:
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"
