Livio Bucher

This article first outlines the structure and scope of application of Art. 61a of the Federal Income Tax Act (DBG) and Art. 24c of the Federal Tax Act (StHG). A key focus is on the interaction with foreign exit taxes. Numerous countries, particularly EU member states acting in accordance with the so-called “Anti-Tax Avoidance” Directive (ATAD), tax unrealized capital gains at the time of departure. Without coordinating measures, there is a risk of economic double taxation if Switzerland taxes the same capital gains a second time. The immigration step-up allows for a corresponding recognition here by reflecting the hidden reserves taxed in the country of departure as increased tax values in Switzerland, which can then be utilized for tax relief through depreciation without requiring a revaluation in the commercial balance sheet.

The crediting of foreign withholding taxes is the key mechanism for avoiding double taxation of dividends, royalties, and interest under Swiss tax law—a system that is quite complex in practice. In this webinar, you’ll gain a concise overview of the requirements and mechanics of the credit system, as well as the new issues arising in connection with the global minimum tax. Benefit from practical insights and concrete case studies on common pitfalls.