New regulation of the enforcement of tax claims: The end of special execution for legal entities
Since January 1, 2025, tax claims against sole proprietorships, partnerships, corporations and other legal entities entered in the commercial register must be asserted in bankruptcy proceedings. The abolition of special execution has far-reaching consequences for companies, authorities and practitioners. This article sheds light on the new legal situation, points out risks, particularly in the enforcement of assessment notices from the FTA or provisionally assessed taxes from the cantonal tax administrations, clarifies key terms such as bankruptcy and mass liabilities and shows what taxpayers need to pay particular attention to in future.
Charitable foundations in tax law - open questions
Non-profit status depends largely on the framework conditions. If these are right, people are willing to make a contribution - be it through donations or volunteering. Tax law provides important incentives: it exempts charitable organizations from tax liability and allows donations to charitable organizations to be deducted from taxable income. Tax law has thus made a significant contribution to the strong growth of the charitable sector in recent years. The foundation sector is booming.
Tax exemption for charitable organizations with a few Basel treats
The charitable sector is of enormous importance in Switzerland. With around 13,900 foundations, Switzerland has the highest density of foundations in Europe. These foundations are managed by around 62,000 foundation board members. Foundation assets are estimated at CHF 140 billion. With distributions of CHF 1.5 to 2.0 billion per year, charitable foundations in Switzerland make a valuable contribution. The recipe for success is in particular the favorable legal framework in Switzerland, first and foremost the standards for tax exemption due to charitable status.
Tax exemption for charitable institutions - New practice definitions in Zurich
This article discusses the new practice in the Canton of Zurich regarding the tax exemption of charitable institutions, which has been published since February 2024. First, procedural issues, in particular the application for tax exemption, are discussed. It then looks at the key points of the practice determinations, i.e. compensation for governing bodies, activities abroad and entrepreneurial funding models.
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.
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.
