Ariane Grenon practices in all fields of Swiss tax law, including corporate and personal taxation as well as philanthropy.
Intercantonal scope of an expense policy
A taxpayer residing in canton of Vaud receives from his Geneva based employer a lump-sum allowance for the use of his private vehicle for business purposes according to an expense policy approved by the Geneva tax authorities.
Ne bis in idem? no…
The ne bis in idem principle does apply to tax evasion and complicity in tax evasion. However, the Federal Court […]
Sale of a shareholding of less than 10% from a participation of more than 10% – no entitlement to participation exemption
In a decision intended for publication (2C_950/2021), which confirms a previous decision (2C_701/2015) after having confronted the criticism of the […]
Transfer of real estate to private assets and donation of real estate – the donation ends the deferral
The Federal court confirmed this in a case concerning a farmer from Vaud who, after having stopped his independent activity, gave parcels of land to his children.
VAT – artwork is like a private airplane: the deduction of input tax should not be claimed abusively…
This is what the Swiss Federal Supreme Court has decided in a decision to be published (2C_263/2020, 10.12.2021).
Change of manager of a real estate fund – collection of transfer duties admitted by the Federal Court
In a decision intended for publication concerning a contractual real estate fund holding real estate in particular in the canton of Fribourg, the Federal Court has confirmed that the canton may levy a transfer tax on the transfer of the fiduciary ownership of the real estate from the former fund management to the new one.
Real estate swap between pension fund and investment foundation: tax deferral on real estate gains
A pension fund transfers all of its real estate to an investment foundation (active exclusively in the management of pension assets) in exchange for rights in the foundation attached to a group of properties including (but not limited to) the transferred properties.
Request for information on bank accounts held by a trust: the characteristics of the trust are irrelevant
The Federal Supreme Court has recently confirmed this in two decisions rendered in relation to requests for information from the Indian tax authorities concerning beneficiaries of irrevocable and discretionary trusts.