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Immigration Step-Up When Moving to Switzerland
Note: This language version is an automatically generated translation. The text may therefore contain linguistic and terminological errors.
view in original language (German)Art. 61a DBG and Art.
2. Structure and Scope of Application of the Provision
3. How the Immigration Step-up Works
Through Art. 61a of the Federal Act on Direct Federal Tax (DBG) and Article 24c of the Tax Harmonization Act (StHG), the legislature has enshrined in law the practice—already partially in effect—of tax-neutral recognition of hidden reserves upon becoming subject to taxation in Switzerland. The purpose of this provision is to ensure that, when companies or businesses with hidden reserves arising abroad relocate to Switzerland, Swiss taxation primarily captures the future v