Tax Aspects of Financial Restructurings
Circular No. 32a of the Federal Tax Administration (FTA), published on January 20, 2025, deals with the tax treatment of restructuring measures for corporations and cooperatives.
Whether you’re founding, expanding or exiting a business – tax considerations are key to strategic decisions.
We provide support wherever you need it, from restructuring and transactions to implementing new accounting standards and optimising your capital structure. Our solutions can be tailored to your business, taking account of tax obligations and your strategic goals. From analysis to implementation, you can rely on our expertise at national and international level.
Our services for business enterprises
- Preparing proposals for optimisation and concepts for existing structures
- Providing advice on locations, migration and relocations of functions
- Implementing commercial distribution, holding, financing and IP structures
- Avoiding double taxation at international and intercantonal level
- Optimising the taxation of international profit repatriations
- Providing advice on real estate transactions
- Coordinating international issues with our network
- Providing transfer pricing services
- Company formations and set-up of branch offices
- Transaction advice on mergers & acquisitions
- Carrying out due diligence
- Post-transaction integration and structuring
- Representing clients in tax matters vis-à-vis authorities and in appeal procedures
- Obtaining binding information and tax rulings
- Accompanying accounting / tax audits
- Preparing tax returns
- Year-end planning including calculating the tax provisions and tax expense
- Checking tax assessments and tax invoices
Corporate Tax Factsheets
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Tax
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2 min read
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05 Sep 2025
Tax
Waivers of claims by shareholders: The accounting treatment is decisive for the exemption from Swiss corporate income tax.
The accounting treatment of waiver income is crucial for determining its exemption from Swiss corporate income tax. Recently, the Swiss federal tax authorities issued a new circular letter (number 32a) addressing the financial restructuring of corporations and cooperatives. According to this guidance, waiver income from shareholders that is directly recorded in the company’s equity should always be exempt from Swiss corporate income tax.
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1 min read
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05 Feb 2025
Tax
Tax-recognized interest rates for advances or loans 2025
Swiss Federal Tax Administration (FTA) annually publishes recognized interest rates applicable for tax assessments of advances and loans in Swiss francs and in foreign currencies.
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2 min read
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30 Jan 2025