Case studies, basic paper and detailed solution notes by Remo Keller and Michael Schwager. This content was part of the workshop at the ISIS seminar "Pensions and Insurance" on September 22/23, 2025
Note: This language version is an automatically generated translation. The text may therefore contain linguistic and terminological errors.
view in original language (German)Laura Meier, 34 years old, lives in Zurich. Since 2024, she has been working as a marketing manager for Nordlicht GmbH, a medium-sized German company. She works exclusively remotely from Switzerland. Nordlicht GmbH does not have a permanent establishment in Switzerland. Laura receives her salary directly from Germany, without deductions for AHV, IV, EO, or BVG. She also does not have insurance in Germany.
Unlike the basic scenario, the situation has changed in that Laura has been working as a marketing manager for BrightWave Ltd., a company based in London (UK), since 2024 and therefore receives a monthly salary directly from London, again without deductions for AHV, IV, EO, or BVG.
How does the assessment change?
Unlike the basic facts, Laura now also receives an additional allowance of CHF 2,000, which is explicitly intended to cover the costs of a workspace in her apartment.
Laura Meier, 34 years old and residing in Zurich, has been offering marketing services to companies throughout the DACH region since 2024. One of her main clients is Nordlicht GmbH, based in Hamburg. Her collaboration with this company is project-based, with no fixed working hours and no obligation to follow instructions. Laura performs her work entirely remotely from her residence in Switzerland. She issues invoices for her services and receives a fee of 90 euros per billable hour. She bears all expenses, the necessary infrastructure, and her social security contributions herself. There are no obligations under an employment contract; in particular, there is no entitlement to continued pay or vacation. Externally, Laura operates under the name “Meier Marketing Solutions,” but in reality, she is fully occupied with projects for Nordlicht GmbH.
How do you classify Laura’s status based on this adjustment of the facts?
Laura Meier, 34 years old and residing in Zurich, has been offering marketing services to companies throughout the DACH region under the name “Meier Marketing Solutions” since 2024. Among her most important clients is Nordlicht GmbH, based in Hamburg. Since mid-2025, she has expanded her client portfolio and now also serves Alpenblick AG, based in Zug, as well as Visiona GmbH in Vienna. Her collaboration with clients is project-based, with no fixed working hours and no obligation to follow instructions. Laura performs her work entirely remotely from her residence in Switzerland. She invoices between 90 and 110 euros per hour for her services. She bears all expenses and the necessary infrastructure herself. There are no obligations under an employment contract; in particular, she is not entitled to continued pay or vacation time. Externally, Laura operates under her company name, maintains her own website, and uses her own infrastructure to provide her services.
How would you characterize Laura’s status in this case?
Albert Steiner works for the Aarau Cantonal Hospital, where he serves as chief physician and heads the cardiology department.
He has a public-law employment contract for an 80% workload. His annual salary is CHF 280,000, and social security contributions are paid by the employer.
In addition, he holds a consultation hour for private patients at the Hirslanden Clinic one day per week. The clinic handles all administrative work (appointment coordination, billing, etc.) for 15% of the fee. Additionally, he pays a flat-rate room rental fee of CHF 800 per day. This results in a net income of CHF 100,000.
For BVG purposes, his insured salary is CHF 354,275 (280,000 + 100,000 minus the 2024 coordination deduction of 25,725).
In 2024, Albert Steiner made a lump-sum contribution of CHF 150,000 to his 2nd pillar pension plan; he also paid CHF 7,056 into his 3a pillar in 2024.
Albert Steiner lives in Baden AG with his wife and their two minor children.
Same basic facts: In 2024, Albert Steiner again made a contribution of CHF 150,000 to the 2nd pillar and paid CHF 7,056 into the 3a pillar.
The Steiner family moved from Freiburg, Germany, in 2023. After moving to Switzerland, Albert Steiner took advantage of the option for voluntary insurance through the Berlin Medical Association’s pension fund and paid the minimum annual contribution of the equivalent of CHF 6,000.
Do the contributions to the Berlin Medical Association, as well as the fact that the family moved from abroad in 2023, affect the determination of Albert Steiner’s taxable income?
Albert Steiner resigned from his positions at KSA and Hirslanden as of December 31, 2023, and started his own business as a consultant for hospitals.
The withdrawal capital from the pension fund amounted to CHF 2,500,000 as of December 31, 2023. Albert Steiner had his pension assets of CHF 2,500,000 from the 2nd pillar paid out.
The sole proprietorship is not registered in the Commercial Register, and there is no website.
In connection with the 2024 tax return, financial statements for the sole proprietorship were submitted. These included various expenses for home office rent, internet costs, communication costs, vehicle costs, training costs as a golf instructor, as well as meal expenses incurred during visits to the golf course.
These expenses are offset by consulting income of CHF 2,500 and a fee of CHF 2,000 for a presentation.
The result shows a loss of CHF 25,000. There is no balance sheet.
Is Albert Steiner to be classified as self-employed?
In connection with the financial statements of the sole proprietorship submitted with the 2024 tax return, expenses were reported for the rental of infrastructure in hospitals, cost-sharing contributions toward personnel costs at the hospitals in Aarau, Baden, and Solothurn, home office rent, internet costs, communication costs, vehicle costs, training costs as a golf instructor, meal expenses incurred during visits to golf courses, as well as depreciation for the newly purchased vehicle and IT equipment. These expenses are offset by revenue of CHF 120,000, consisting of various payments received for services rendered to hospitals and health insurance companies.
The result shows a loss of CHF 55,000.
Is Albert Steiner to be classified as self-employed?
Albert Steiner is very pleased with the strong start to his self-employment. After just two months, he is already struggling to keep up with the heavy workload. In addition, the complex consulting mandates are exposing him to increasing liability risks that his liability insurance does not fully cover. Therefore, after only three months, he decided to give up his self-employment and convert his sole proprietorship into a corporation as of October 1, 2024. Following the conversion, he receives a monthly gross salary of CHF 20,000 from his company.
Is it sufficient if the self-employment lasted only 3 months?
Albert Steiner founded Spitalberatung Steiner AG in January 2024. As of July 1, 2024, he resigned from his position as chief physician at KSA and became self-employed as a consultant. The withdrawal capital from the pension fund amounted to CHF 2,500,000 as of June 30, 2024. Albert Steiner had his pension assets of CHF 2,500,000 from the 2nd pillar paid out.
Albert Steiner subsequently provides consulting services to various Swiss hospitals, which are invoiced and collected by Spitalberatung Steiner AG.
According to the financial statements as of December 31, 2024, this results in a profit of CHF 110,000.
The details of the income statement show that Albert Steiner invoices exclusively to Spitalberatung Steiner AG, and the service revenue of CHF 180,000 is offset by expenses of CHF 70,000.
Spitalberatung Steiner AG, in turn, reports a net profit of CHF 150,000.
In 2025, an exit takes place: A private equity fund acquires Top Solution AG. At the company’s headquarters in Zug, a tax ruling was obtained that recognizes the formula value as valid and confirms that the capital gain is tax-exempt after a holding period of five years.
The cantons of Aargau and Vaud, however, reject the formula value as unsuitable and do not recognize the tax exemption of the excess profit.
How does the compensation fund of the Canton of Zug assess this case with regard to social insurance?
Hans Grossfuss was able to acquire a stake in Top Solution AG six years ago. Since he is notoriously short on cash despite a very good income, he was unable to pay for the acquisition of the shares in Top Solution AG at the very favorable formula value.
Top Solution AG therefore granted him an interest-free loan. In the meantime, he has been able to repay only 40% of this loan.
Will anything change for him? What else needs to be considered?
