Important Supreme Court ruling confirming tax-free step-up
The Federal Supreme Court on 18 February 2014 rendered an important ruling on the tax-neutral step-up of hidden reserves of a Geneva-based holding company. The hidden reserves had been created while the holding company enjoyed an income tax exemption under the cantonal holding company regime. After the company had changed its tax status into an ordinarily taxed company, it sold some of its assets at a considerable gain. In its corporate tax return, the company deducted losses from earlier periods from the realised capital gain and thus reported zero taxable profit.
The Supreme Court confirmed the approach taken by the Geneva Cantonal Tax Authorities and the cantonal courts that losses accrued during the period of the exempt tax status could not be deducted from profits realised after the corporate tax exemption had fallen away…
Click on the link below to read the rest of the Bär & Karrer briefing.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.