Circular No. 5a of the FTA (German only)

In this circular letter, the federal tax consequences (direct federal tax, WHT and stamp duties) on reorganization events are reproduced at the corporate level and for the unitholders.

In addition to general editorial changes, the updated Circular Letter No. 5a on restructurings includes the legal adjustments (in particular, Federal Law of March 23, 2007 on the Improvement of the Tax Framework for Entrepreneurial Activities and Investments [Corporate Tax Reform Act II], as well as Federal Law of September 28, 2018 on Tax Reform and AHV Financing [TRAF]), as well as the relevant rulings of the Federal Supreme Court and practice adjustments of the Federal Tax Administration (FTA) issued since the publication of Circular Letter No. 5.