In two rulings handed down in the first half of 2024, the Swiss Supreme Court has ruled on two important issues arising in the field of Swiss withholding tax, particularly in the context of a withholding tax audit, namely the starting points for (i) the 7-year limitation period provided for by the Swiss DPA (6B_1005/2021) and (ii) the interest due on withholding tax that has not been paid on time.
Etienne von Streng honored by Best Lawyers 2025
We are delighted to announce that Etienne von Streng has been recognized by Best Lawyers 2025.
9C_680/2022 : Application of art. 37b LIFD (preferential taxation at the end of self-employment)
The Federal Court confirms that the preferential taxation of hidden reserves provided for in art. 37b LIFD (cessation of self-employed […]
Deductibility regime in connection to the purchase of a condominium share
In ruling 9C_391/2023 (intended for publication), the Swiss Federal Court ruled that the compensatory payment made by the buyer of […]
Change of management within a real estate fund – transfer duty?
In ruling 9C_312/2023 of December 7th 2023 (to be published), the Swiss Federal Supreme Court (SFSC) confirmed the precedent set […]
Stamp tax exemption (over-indebtedness) – the elimination of losses in the accounts is indeed necessary
In a ruling proposed for publication (9C_610/2022 of September 7, 2023), the Federal Supreme Court confirmed the Federal tax administration’s (FTA) interpretation […]
Open or hidden capital contributions: same treatment (income tax)
In a judgement intended for publication, the Swiss Federal Supreme Court has invalidated the practice of the Federal Tax Administration.
Building maintenance costs: The “Dumont practice” (really) abolished
The legislator had abolished the Dumont practice in 2010 by expressly allowing the deduction, as maintenance costs, of “costs for the restoration of recently acquired real estate”.
STRENG SA is happy to announce the appointment of Ariane Grenon as Counsel
Ariane Grenon practices in all fields of Swiss tax law, including corporate and personal taxation as well as philanthropy.