Restructuring is part of everyday business life. The notification procedure makes it possible to handle certain transfers of assets in a VAT-efficient manner without triggering unnecessary liquidity pressures. However, correct application requires that the legal and time-related requirements are identified and met at an early stage.
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.
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.
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.
A VAT Health Check ensures that a company’s value-added tax obligations are correctly fulfilled and associated compliance risks are minimized. The analysis identifies potential weaknesses in VAT processes and classifications, offering opportunities to optimize and reduce risks while achieving more efficient tax management.
Switzerland suspends the application of the most-favoured-nation clause based on a protocol to the tax treaty between Switzerland and India. Dividend distributions from Switzerland to India until December 31, 2024, will still benefit from this clause.
