Category: Tax

The Case: Since mid-2025, it has become increasingly clear that the United States intend to withdraw from the OECD minimum tax framework; a final decision is expected by the end of this year. The Commentary: For Switzerland this development primarily entails greater uncertainty. A unilateral suspension of the minimal tax…

The Case: L’initiative pour l’avenir, up for a nationwide vote on 30 November, has revived a familiar question: How does Switzerland’s inheritance tax regime compare with the one of its OECD peers? The Commentary: While Switzerland does not tax inheritances dramatically less than others, its highly decentralized cantonal system and…

The Case: In the initiative text one cannot find any definitions of as to who is taxable (subject). Consequently, even if the Swiss population did vote in favour of the initiative, the Federal Council would still be required to issue implementing ordinances within three years* before any inheritance cases could…

The Case: Does the tax-neutral transfer of commercial property to a company constitute tax avoidance? The Commentary: In principle, the tax-neutral transfer of commercial property to a company cannot be classified as tax avoidance per se. The decisive factor is whether the arrangement fulfils the three cumulative elements: Objective element,…

The Case: The Young Socialists’ initiative proposing a 50% federal estate tax on estates exceeding CHF 50 million is scheduled for a nationwide vote on 30 November 2025. The Commentary: Legal vacuum: No definition as to who is subject to tax!

The Case: Information obtained through international administrative assistance in tax matters may only be used in respect of the person concerned. The Commentary: The French tax authorities had requested administrative assistance regarding a French national who had claimed to be resident in Switzerland, suspecting that he had actually been living…

The Case: The Federal Tax Administration (FTA) has published its guide on lump-sum taxation in the Cantonal Gazette; see also the tax folder “Lump-Sum Taxation” (see Article 14 of the Federal Act on Direct Federal Tax (DGB) – below). Furthermore, the tax folder “Personal Tax – Poll Tax” has been…

The Case: As of 1 January 2026, properties in the Canton of Zurich will be revalued for tax purposes. The property tax values and imputed rental values will be adjusted in order to reflect price increases in the real estate sector, and they are expected to increase significantly in most…

The Case: The Federal Tax Administration has updated the lists of amendments to laws and ordinances concerning the direct federal tax, the value added tax, the withholding tax and the stamp duties. The Commentary: The list concerns the amendments to laws and ordinances for the years 2026 to 2028 that…

The Case: The imputed rental value tax will only be abolished if the people and cantons approve Art. 127 para. 2bis of the Federal Constitution, which grants the cantons the right to levy a special tax on predominantly owner-occupied secondary properties. The Swiss will to to the polls on 28…

The Case: Iwan and Manuela Wirth, co‑owners of Hauser & Wirth Gallery, officially relocated to Switzerland in early June 2025, as confirmed by UK Companies House documents. The Commentary: In a statement in the Financial Times, the gallery emphasized the couple’s Swiss nationality, the headquarters in Switzerland, current projects in…