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ISIS) seminar "Tax aspects of corporate finance, including reorganisation topics" (seminar folder)

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Case studies, detailed solution notes and slides: Here you will receive all documents (workshops and presentations) according to the following description from the ISIS) seminar "Tax aspects of corporate financing, including reorganisation topics" of 20.04.2021 under the direction of Susanne Schreiber, which took place online.

The complete PDF of the seminar folder can be downloaded for CHF
The corresponding case solutions can be purchased for CHF
(introductory price)
can be purchased in the shop.
The workshops are also available individually in the "Documents" section.
The case solutions and other documents can be obtained free of charge in the shop.


In the national and cross-border sphere, a wide range of questions arise in corporate financing, especially in intra-group financing. In financially strained situations, special instruments such as bullet, subordinated or convertible loans are often necessary and the well-known - but often controversial - restrictions on hidden equity must be observed.

If a company is in a restructuring situation, it is all the more important to avoid unnecessary tax consequences (and liquidity outflows). Accordingly, debt waivers, contributions and restructuring for reorganisation must be well planned.

The tax-efficient allocation of debt, the so-called debt push down, is often not a simple undertaking from a Swiss and international perspective and can have an impact on the so-called deduction for self-financing (NID).

An overview of current developments in the field of corporate financing and restructuring will be provided and structuring options and pitfalls will be analysed on the basis of practical examples.

Topics and speakers

Intra-group financing and hidden equity (learn more)

Practical examples on the calculation of hidden equity in the case of several loans including withholding tax as well as consideration of own goodwill, hidden equity in connection with the reduction of capital tax in the canton of ZH, interplay between COVID-19 loans and hidden equity, requirements for the third party comparison taking into account the negative interest rate environment and safe haven interest rates in downstream constellations.

M.A. HSG René Hintermann, Certified Tax Expert, Director Tax & Legal at Deloitte AG, M.A. HSG in Accounting and Finance

lic. rer. publ. HSG Eva Mäki, LL.M. Taxation, Tax Commissioner mbA at the Cantonal Tax Office Zurich

Reorganisation and restructuring / loss utilisation strategies (learn more)

Practical examples of restructuring mergers and tax consequences depending on the direction of restructuring, tax options and limits of loss utilisation ("loss refresher"), (partially) tax-effective restructuring, incl. cross-border aspects.

MLaw Martin Dubach, attorney-at-law, certified tax expert, Tax Director at Swiss International Airlines AG

MLaw Fabienne Limacher, LL.M., attorney-at-law, certified tax expert, partner at Walder Wyss AG Zurich

Debt waiver / debt transfer / debtor warrants and profit participation certificates (learn more)

Case studies on debt waivers with/without debtor warrant or profit participation certificate, tax-neutral vs. tax-effective debt waivers, effects on prime costs and previous value adjustments, issue tax and withholding tax consequences.

Dr. oec. HSG Felix Schalcher, certified tax expert, Senior Group Tax Manager at Hitachi ABB Power Grids AG Zurich

Lic. iur. Andrea Jost, lawyer, certified tax expert, Senior Manager at Ernst & Young AG Zurich

Special topics of financing - bullet loans, partiar loans, convertible loans,safe haven interest rates (learn more)

Practical examples on withholding tax, stamp duty, income tax and profit tax consequences, in particular the discrepancy between the time of taxation for profit tax and withholding tax; tax aspects of convertible loans and convertible bonds, current FTA practice on safe haven interest rates.

Lic. iur. Stefan Oesterhelt, LL.M., attorney-at-law, certified tax expert, partner at Homburger AG

Pascal Schild, Certified Tax Expert, Tax Expert Rulings and Transfer Pricing at the Federal Tax Administration (External Audit Division)

Tax-efficient allocation of financing/debt push down and deduction on own financing (learn more)

Design options for a debt push down in the national and international context,optimisation and effects on the deduction for equity financing, case studies on debt push down (mergers, leveraged dividends / share buybacks, intra-group sales, transfer of profit potential etc.).

Dr. iur. Gernot Zitter, LL.M., certified tax expert, partner at KPMG AG Zurich

Lic. oec. HSG Claudia Schaub, Certified Tax Expert, Director at KPMG AG Zurich


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