精东影业

On January 20, the Swiss Federal Tax Administration (FTA) published the new Circular No. 32a, explaining the tax consequences from its perspective in cases of corporate and cooperative company restructuring for the purposes of direct federal tax, withholding tax, and stamp duties. The update was necessary to account for, on one hand, the adjustments made to Circular No. 5a on restructuring published in 2022 and, on the other hand, to align tax practices regarding restructurings with the case law of the Swiss Federal Supreme Court. During the webinar, the discussion will first cover accounting aspects and auditor obligations in the presence of a deficit balance sheet based on the Swiss Code of Obligations, as well as the need for corporate restructuring. Subsequently, in line with Circular No. 32a, the tax treatment of debt waivers by shareholders and third parties, as well as transactions between sister companies, will be examined. Particular attention will be given to the topic of restructuring mergers, with a focus on cases involving the absorption of a subsidiary (鈥渦pstream merger鈥�) and restructuring transactions between sister companies. Finally, the tax implications of both implicit and explicit restructuring in relation to issuance stamp duty will be explained.

Program and Speakers
Deficit Balance Sheet and the Need for Restructuring: Accounting Law Aspects and Auditor Obligations
Paolo Gattigo
Lic. rer. pol., Executive Master in Public Administration (EMAP), Partner, Branch Manager, BDO Lugano

Tax Treatment of Restructuring Measures: Case Studies on Debt Waivers and Transactions Between Sister Companies and Third Parties
Matteo Gamboni
Certified Tax Expert, Senior Manager, PwC Lugano

Restructuring Mergers
Lisa Airoldi
M.A. HSG, Swiss Certified Tax Expert, Owner, LCA Tax Consulting SA, Locarno

Implicit and Explicit Restructuring: Tax Implications for Issuance Stamp Duty
Massimo Bianchi
Certified Tax Expert, Owner of a Tax and Business Consulting Firm, Lugano

Cost
CHF 350.-
Discount of CHF 50.- for FTAF members and partner organizations.

Registration
Registration Deadline
Friday, September 5, 2025