Edition 3/2025

Tax authorities are increasingly automating their processes and making greater use of AI. They are also required to do so due to the obligation to act efficiently and effectively. Building on this, the authors examine what requirements the ongoing automation must meet in light of the principle of legality, the duty to audit and investigate, and the duty to provide justification, and identify areas where legislative action is needed.

In privately held corporate groups, it is not uncommon to find partnerships and other person-based legal entities—such as trusts, foundations, or private individuals linked by shareholder agreements—at the top of the structure. This article analyzes how such legal entities are to be treated under Swiss and international supplementary tax laws and to what extent the provisions of Swiss income and profit tax law influence this.

In its ruling of November 26, 2024, the Tax Appeals Court of the Canton of Zurich confirmed that a taxpayer may terminate his self-employment and thereby claim taxation of liquidation gains even if he purchases a property from his former business assets, has it renovated together with another property acquired from his brother, and rents it out, since the activity associated with the two acquired properties does not constitute a continuation of self-employment but rather serves as a private investment.