News on the taxation of corporate restructurings (2026)
- Entreprises
In practice, corporate restructurings raise a variety of tax issues - in particular when shareholdings are spun off, real estate is converted, sister companies with loss carryforwards are merged or demergers are completed by selling at a lower price. Using practical case studies, Stefan Oesterhelt and Daniel Strahm show what tax consequences are associated with the spin-off of participations (including minority participations of less than 10%), when it is possible to invoke Art. 12 para. 4 lit. a StHG for real estate gains tax and under what conditions the conversion of an ordinary company into an AG can be tax-neutral. It also deals with mergers with loss carryforwards and cantonal differences in Basel, Berne and Zurich. The solutions provide you with the necessary tools to plan complex restructurings safely and to recognize tax obstacles at an early stage.
