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Own shares and participation plans often go hand in hand. A company may issue its own shares or purchase them from shareholders in order to distribute them to its employees through a participation plan. The topic of own shares, particularly in light of recent changes in accounting law, has been the subject of several important rulings by the Federal Supreme Court, which have significantly altered the practices of tax authorities: initially in relation to capital tax, subsequently to VAT, and finally to corporate income tax.

It is also important to understand what happens once the waiting period expires. Therefore, it is essential to be familiar with the development of the Federal Supreme Court’s case law regarding the accounting treatment—and, above all, the tax treatment—of own shares. To this end, several practical cases will be presented, illustrating the tax consequences for both shareholders and companies, in terms of direct taxes and withholding tax.

Particular attention will be paid to situations in which a company intends to issue or repurchase its own shares to grant them to employees. In this context, the main tax considerations—and others—to be taken into account when a company decides to adopt a participation plan for its employees will be highlighted. Special focus will be given to issues related to the ideal formula value, share lock-up periods, and the practices adopted by the tax authorities.

Finally, the importance of employee participation in start-up companies will be emphasized, as it represents an effective tool not only to retain employees but also to enable them to take part in the company’s potential success through the acquisition of shares.

All of these topics, which are highly relevant to companies, shareholders, and employees alike, will be covered in the webinar organized by the ¾«¶«Ó°Òµ Tax & Legal Competence Centre.

Programme and Speakers
The legislative and case law evolution regarding the accounting and tax treatment of own shares
Francesca Codoni, LL.M. in International Taxation, M.A. in Management, Counsel, Tax Partner AG, Zurich

Practical examples concerning accounting and tax aspects for companies and shareholders (especially with private assets holdings) in the case of share buyback and resale for participation plans
Luca Aspesi, Attorney-at-law, Swiss Certified Tax Expert, Senior Advisor, Tax Partner AG, Zurich

Tax aspects to consider when planning a new employee participation plan (shares only)
Sebastiano Garufi, PhD, Attorney-at-law, Adjunct Professor of Tax Law at Bocconi University, Milan, Partner at Altenburger Ltd. legal + tax, Lugano and Zurich

Tax treatment of participation plans for start-up companies
Sharon Cina, Attorney-at-law, Division of Contributions, Central Services, Bellinzona

Fee
CHF 350.–
CHF 50.– discount for members of partner organisations

Registration
Registration deadline
Tuesday, 13 January 2026