During 2025, the Federal Supreme Court addressed several tax law issues of particular interest to those working in this field. First, the High Court ruled on the issue of capital contributions and the formal reporting and registration requirement for reserves, so that they can be considered exempt from withholding tax in the event of distributions to shareholders. This decision has important practical implications. Another important case concerned the transfer of an asset from commercial to private ownership, a transaction which, under tax law, is equivalent to a disposal. In this case, the judges focused on the objective and subjective elements that qualify the transfer of real estate to private ownership. In matters of social insurance, the Federal Supreme Court also classified asymmetric dividend distributions as income from employment, and therefore subject to AHV contributions. It is therefore important to understand the criteria developed by the High Court to distinguish an asymmetric dividend from earned income for the purposes of AHV liability. The webinar, organized by the CCTG in collaboration with the FTAF, finally addresses two additional decisions: first, the issue of a simulated loan granted to the shareholder by the company, which may be classified as a disguised distribution of profits; and second, the situation of a taxpayer domiciled abroad with limited tax liability in Switzerland who, during the tax period, becomes subject to unlimited tax liability. In this context, the Federal Court clarified whether the taxpayer must file one or two tax returns for the same period.

Program and Speakers
Principle of Capital Contributions: Clarifications on the Reporting Obligation and Recording of Capital Contribution Reserves (Federal Court Decision No. 9C_690/2023 of March 21, 2025)
Giuseppe De Pascalis
Lawyer, certified tax expert, Senior Manager Swiss Tax, Fidinam Partners, Lugano
​​​​​
Taxation of Latent Reserves Transferred from Commercial to Private Assets (Federal Court Decision No. 9C_143/2025 of July 31, 2025)
Graziella Kähr
MAS SUPSI in Tax Law, Deputy Director of the National Tax Competence Center, Fidinam Partners, Lugano

Asymmetric Dividends and Income from Gainful Employment (Federal Court Decision No. 9C_272/2024 of January 20, 2025)
Patrick Cuomo
BSc SUPSI in Business Administration, Real Estate Trustee and Accountant, Fiduciaria Antonini SA

Shareholder Loan, Loan Repayment, and Cash Benefit (Fiduciary Court Ruling No. 9C_462/2024 of May 9, 2025)
Alice Barozzini
MSc in Economics and International Politics, Specialist in Finance and Accounting, Tax Inspector at the Taxation Office for Legal Entities (UTPG) of the Canton of Ticino Tax Division

Daniele Annibale
MAS SUPSI in Tax Law, Tax Inspector at the Taxation Office for Legal Entities (UTPG) of the Canton of Ticino Tax Division

Transition from Limited to Unlimited Liability in Switzerland during the Same Tax Year (Fiduciary Court Ruling No. 9C_416/2024 of August 14, 2025)
Samuele Vorpe
Full Professor of Tax Law at SUPSI, MAS SUPSI in Tax Law, Head of the SUPSI Tax and Legal Competence Center, Of Counsel at COLLEGAL Attorneys at Law, Lugano

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

Registration
https://bit.ly/webinar-16-03-2026

Registration deadline
Friday, March 13, 2026