The Tax Competence Centre of SUPSI offers a webinar aimed at presenting and analysing various practical cases concerning company restructuring. We will first focus on the creation of a holding company, in particular through the contribution and/or transfer of shares. In this context, it may happen that an individual decides to reorganise his assets by holding his various participations through a single holding company. Furthermore, in a group of companies it may happen that there is a need, for various reasons, to reorganise its corporate structure by transferring certain participations under the control of a new holding company. In both cases, the result can be achieved by transferring (or possibly otherwise transferring) the shares of the participations into a new or existing company, thus effectively creating the holding company. In the first talk, we will address, through various practical cases, the tax issues arising in connection with the creation of a holding company by contribution or transfer of shares. Afterwards, we will deal with spin-offs of legal entities, i.e. when a company transfers one or more parts of its assets to another company. According to Art. 61 para. 1 LIFD, demergers are tax-neutral, but there are several conditions to be met and the tax effects, in the absence of the requirements for neutrality, can be particularly significant. Next, the focus will be on practical cases of current relevance in the area of mergers of legal entities,
highlighting particular complexities that characterise these transactions both in the national and international context. Particular attention will be paid to analysing the tax implications of such mergers for corporate income tax and withholding tax purposes. preventative. Finally, from the point of view of the tax authority, it will be explained how a correct and comprehensive tax ruling application should be submitted in the context of corporate restructurings.
 

Programme and Speakers
The creation of a holding company, in particular through the contribution and/or transfer of shares
Michel Morelato
Lawyer, LL.M., Tax expert dipl. fed., Law firm Bär & Karrer SA, Lugano

Demergers of legal entities
Massimo Bianchi
Tax expert dipl., owner of a tax and business consulting firm, Lugano

Mergers of legal entities
Francesca Codoni
LL.M. in International Taxation, M.A. in Management, Senior Advisor, Tax Partner AG, Zurich

Corporate restructurings: how to file a ruling
Egon Modesti
Tax Expert CSI, Tax Inspector at the Office for the Taxation of Legal Entities of the Taxation Division, Bellinzona

Daniele Annibale
MAS in Tax Law, Tax Inspector at the Taxation Office for Legal Entities of the Taxation Division, Bellinzona

Cost
CHF 350.
CHF 300.- for members of partner institutions

Registration
https://bit.ly/webinar-18-01-2024

Registration deadline
Monday 15 January 2024