Taxes

The STAF introduces a special rate solution for companies that allows a special tax rate on profits from hidden reserves for five years. This rate is determined at the cantonal level and does not require deferred taxes on the balance sheet.

From 2020, the tax privileges for holding, domicile, and mixed companies will end, with transitional provisions such as the step-up to avoid over-taxation. The step-up allows the tax recognition of hidden reserves without commercial legal recording.

The AHV tax proposal eliminates the special tax status for holding and other companies from 2020 onwards. Due to this elimination, the treatment of hidden reserves and their tax-optimized depreciation until 2024 is a central point.

Basel-Stadt reduced the profit tax to 13% and with patent box deductions to up to 11%. The tax reduction applies retroactively from January 1, 2019.

The withholding tax of 35% on dividends can be fully reimbursed for actors residing in Switzerland, for foreigners the respective double taxation agreement applies. The Dutch foundation "A." received a refund of only 20% of the withholding taxes, as it held under 25% of the shares and lost a discrimination lawsuit.

Dissatisfied taxpayers can use reconsideration or correction to challenge decisions or correct errors. Reconsideration is flexible and without deadline, correction fixes clear errors within five years.

In cases of serious, identifiable defects, a tax decision can also be declared void after the deadline has passed. This happened in the case of a female doctor, whose excessive income assessment was declared void by the Federal Court.

In case of an objection to a tax assessment, the appeal must be made within 30 days; missed deadlines may be restored under serious reasons such as illness. Late appeals without valid reasons will not be accepted.

Dissatisfied taxpayers can contest tax decisions through objection, appeal, and complaint before they become legally binding. If rejected at the cantonal level, there is still the option to go to the Federal Court, following strict deadlines and conditions.