corporate migrations; selected tax aspects from a swiss tax perspective

Daniel U. Lehmann


Corporate income taxes: Step-up in tax basis?

•Direct migration:

Like formation of new company, step-up available
Tax effective amortization of assets available (intangibles?)

•Indirect migration:

Tax basis of Company remains unchanged
Shares in Company in the accounts of NewCo: Capitalization at "transfer value" (NAV, fair market value)
No tax effective amortization of goodwill available (impairment)


Corporate income tax: Use of existing tax loss carry-forwards?

•Direct migration: No (formation of new company, new "tax life" starts)
•Indirect migration: Depends on country of residence of Company


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