Switzerland: Tax

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Article
Financial Restructuring: Mind The Tax Traps
Companies undergoing financial restructuring often focus on balance sheet repair and liquidity preservation. Yet the tax consequences of restructuring measures can be just as significant as their corporate law effects. Depending on how contributions, debt waivers or recovery rights are structured and recorded in the accounts, the same economic outcome may trigger different consequences for corporate income tax, issuance stamp tax and capital contribution reserves.
Switzerland Tax
PL
Pestalozzi Attorneys at Law
Article
Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?
The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
Switzerland Tax
LL
Loyens & Loeff
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Tax Treaties

Article
Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?
The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
Switzerland Tax
LL
Loyens & Loeff
Article
Swiss Federal Supreme Court Limits Protection Of Attorney-Client Privilege In International Tax Assistance Proceedings
In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.
Switzerland Tax
BK
Bär & Karrer
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Inheritance Tax

Article
The Swiss Lump-sum Taxation After The Introduction Of Individual Taxation: New Opportunities For Individuals
Switzerland's shift to individual taxation by 2032 will fundamentally reshape the country's lump-sum taxation regime for internationally mobile individuals. The reform removes the requirement that both spouses must qualify simultaneously for lump-sum taxation, creating new planning opportunities for mixed-status couples while introducing complexities around asset allocation and minimum tax thresholds.
Switzerland Tax
LL
Loyens & Loeff
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Income Tax

Article
Financial Restructuring: Mind The Tax Traps
Companies undergoing financial restructuring often focus on balance sheet repair and liquidity preservation. Yet the tax consequences of restructuring measures can be just as significant as their corporate law effects. Depending on how contributions, debt waivers or recovery rights are structured and recorded in the accounts, the same economic outcome may trigger different consequences for corporate income tax, issuance stamp tax and capital contribution reserves.
Switzerland Tax
PL
Pestalozzi Attorneys at Law
See more

Transfer Pricing

Article
Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?
The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
Switzerland Tax
LL
Loyens & Loeff
See more

Latest Videos

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