Stefan Oesterhelt

With the abolition of the imputed rental value, property owners are faced with fundamental new questions: Which maintenance costs are still deductible—for mixed-use properties, vacation homes, properties provided free of charge, or properties rented at a preferential rate? How are contributions to renovation funds and investments in energy-saving measures treated, and what are the rules regarding the deduction of interest on debt? Using eight case studies, this guide systematically examines the practical issues surrounding tax deductions under the new law.

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.

Financing is a key lever in M&A transactions - and at the same time harbors considerable tax risks. These case studies show how the 10/20 non-banking rules and withholding tax apply in complex loan and guarantee structures. The topics covered include syndicated financing, cross-border structures, relocation of registered offices and convertible bonds. The solutions provide you with the necessary understanding to correctly assess financing structures for tax purposes and avoid typical pitfalls.

Case studies and detailed solution tips from Stefan Oesterhelt and Sirgit Meier. The workshop was part of the ISIS seminar "Pensions and Insurance" on September 22 + 23, 2025.

Workshop by Stefan Oesterhelt and Daniel Strahm on the occasion of the ISIS) seminar on June 02 + 03, 2025 entitled "News on the taxation of corporate restructurings"