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During the webinar, selected topics on the taxation of real estate companies will be analyzed according to cantonal, federal, and international law.
First, a definition of a real estate company will be provided, based on the practices and case law developed by the Swiss Federal Supreme Court, followed by an explanation of how such companies are treated for direct tax purposes. Next, relying also on the jurisprudence of the Swiss Federal Supreme Court, an attempt will be made to explain how the taxation (both unlimited and limited) of real estate companies is applied in cases involving ordinary income and profits from the partial or total sale of shares by shareholders, taking into account both inter-cantonal and international tax law.
Another important topic is the tax allocation of real estate companies and professional real estate traders according to conflict-of-law rules developed by the Swiss Federal Supreme Court. Through the analysis of concrete case studies, the webinar aims to highlight the various specific considerations involved in inter-cantonal tax allocation.
Finally, but no less importantly, the discussion will turn to the conventional rule of Article 13 of the OECD Model Tax Convention, which governs the taxing rights on profits derived from the sale of real estate companies in international circumstances — a topic that is highly debated and controversial in academic literature.

Program and Speakers
The Tax Treatment of Real Estate Companies: Practical Implications
Ivan Bottinelli
Certified Tax Expert, Tax Consultant, Cortesi & Associati SA, Lugano

The Taxation of Real Estate Companies in Inter-Cantonal and International Relations
Samuele Vorpe
Full Professor of Tax Law at ¾«¶«Ó°Òµ, MAS ¾«¶«Ó°Òµ in Tax Law, Head of the Center for Tax and Legal Competence at ¾«¶«Ó°Òµ, Of Counsel at COLLEGAL Studio legale e notarile Attorneys at Law, Lugano

Inter-Cantonal Tax Allocation of Real Estate Companies and Professional Real Estate Traders
(presentation in French and Italian)
Daniel De Vries Reilingh
Prof. Dr. iur., Lawyer, LL.M., Certified Tax Expert, de Vries Reilingh Legal & Tax SA, Neuchâtel and Lausanne

Christian Chillà
Lawyer, Partner at MCE Avocats, Lausanne

The Taxation of Profits from Real Estate Companies According to the OECD Model
Marco Greggi
Full Professor of Tax Law at the University of Ferrara

Cost
CHF 350.-
CHF 50.- discount for members of partner organizations

Registration


Registration Deadline
Friday, March 7, 2025