Corporate tax

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Corporate tax

As businesses develop, so do tax liabilities. Forvis Mazars provides a realm of corporate tax services for every stage of a company’s life. The corporate tax team provides tax compliance and advisory services to many Swiss and international groups' companies - from quoted companies down to small owner-managed businesses.

Tax deductibility of vacation provisions

In its decision 9C_192/2024 of 3 July 2024, the Federal Supreme Court dismissed the appeal filed by a Geneva-based company specialising in auditing and tax consultancy. The company requested the deduction of a provision for accrued vacation amounting to CHF 250,000. The Court ruled that this provision did indeed constitute a charge for future risk and that, as such, it was not justified by business...

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Change in practice on interest rates for loans

On 17 July 2024, the Federal Supreme Court made a landmark decision in the case 9C_690/2022. The legal issue revolved around the correct application of the so-called safe harbor interest rates for loans between related parties After a taxpayer deviated from the FTA's published safe-harbour interest rates, the case was taken to the last instance.

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New developments in the area of over-indebtedness

In previous tax newsletters, we have already outlined a brief overview of the changes and amendments to company law that came into force on 1 January 2023. This article will now focus in particular on the effects of the revision to the Swiss Code of Obligations in connection with a reorganisation (over-indebtedness).

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Are you up to date with the company law reform?

The new law, which was adopted by the Swiss Parliament in June 2020 and came into force on January 1, 2023 , brings many changes to the legal framework of Swiss corporations. It aims to make the rules more flexible, modern, and transparent, while also addressing some of the challenges that have been raised over the years.

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New corporate law

The main changes in connection with the new regulations of the corporate law, which entered into force on 1st January 2023, allow greater flexibility for share capital and equity distributions as well as the enhancement in the modernisation of general meeting. Companies have a two-year timeframe (until 1st January 2025) to amend their articles of association according to the new regulations.

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We offer proactive advice, looking at tax issues from all angles. Our team has an in-depth understanding of the industries in which our clients operate and appreciate the issues currently affecting directors and shareholders.

Forvis Mazars provides expert tax advice related to:

  • Advising on business and tax re-structuring
  • Supporting new business set-up and expansion
  • Assisting clients when entering new markets or sectors
  • Improving stakeholder value and returns from a tax viewpoint
  • Advising on the choice of tax efficient structures
  • Assisting clients on financial restructuring, group financing and cash-flow optimisation
  • Advising on global tax minimisation 
  • Mitigating tax risk and due diligence
  • Supporting tax compliance obligations and identifying tax cash out with accurate timing
  • Managing fruitful interactions with the tax authorities in Switzerland and internationally

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