Switzerland: Tax Authorities

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.

At first glance, the utilization of tax losses appears straightforward: losses may be offset against future profits.

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In decision 9C_606/2025 of 24 February 2026, the Swiss Federal Supreme Court held that interest expenses on acquisition debt transferred to a target company through a downstream merger are not deductible where they lack a direct nexus to the target’s own business activity.

In a landmark ruling (9C_606/2025, 24 February 2026), the Swiss Federal Supreme Court has for the first time directly addressed the deductibility of interest following a debt push-down in a leveraged buy-out...

Switzerland's abolition of the imputed rental value (Eigenmietwert) has been widely welcomed as the end of a long-criticised tax burden on homeowners.

Two recent developments have further strengthened the international standing of Swiss stock exchanges. On 1 May 2025, the Swiss Federal Council lifted...

On June 28, 2025, the G7 issued a joint statement that marked a shift in the global tax landscape. The agreement, reached just days earlier between...

The definition of a permanent establishment in Article 5(1) of the OECD Model Tax Convention remains unchanged. However, the Commentary now contains detailed guidance on when a home office, work performed in second...