During the webinar, organized in collaboration with the Ticino Federation of Fiduciary Associations (FTAF), the rules governing unlawful profit distributions will first be examined in depth. This area has been significantly strengthened by the reform of company law through the new Art. 678 of the Swiss Code of Obligations (CO), which now provides for greater responsibility on the part of the corporate bodies. From a tax perspective, the reform has clarified the scope of benefits assessable in monetary terms that are unlawfully received by shareholders, establishing their mandatory restitution. The webinar will then analyse various situations in which the shareholder repays such amounts at different points in time, as well as the conditions necessary to avoid tax consequences for corporate income tax, personal income tax for the shareholder, and withholding tax.
This will be followed by an analysis of the principles, limits, and practice of restructurings through quasi-mergers, also taking into account issues related to transposition. 
Finally, the webinar will focus on the determination of dividends from substance in cases of indirect partial liquidation. The legal requirements of this concept will be outlined, together with the criteria used to quantify the taxable investment income attributable to the selling shareholder in lieu of private capital gains. After a brief theoretical introduction, practical examples will illustrate how the tax authorities determine non-essential excess liquidity held by the company whose shares have been transferred. The session will conclude with an examination of the amendment to Art. 87a(2) LT, introduced in 2023, which extended capital tax relief to companies without commercial activity in Switzerland that are primarily engaged in intragroup financing. Before the reform, such companies were not entitled to any tax relief. The legislative developments leading to the amendment will be reconstructed and, through practical case studies, the webinar will show how the measure has improved the tax regime by aligning the treatment of financing companies with that of holding companies.

Program and speakers
Tax consequences following the repayment of benefits assessable in money by shareholders
Ernesto Gonzalez
Master of Advanced Studies SUPSI in Tax Law, Business Economist SUP, MPP Fiduciaria SA, Breganzona

Restructuring through quasi-mergers: principles, limitations, and practices
Luca Aspesi
Lawyer, Federally Certified Tax Expert, Senior Advisor, Tax Partner AG, Zurich

Quantification of the substance dividend in case of indirect partial liquidation
John Sulmoni
Certified tax expert, Deputy Director of the Division of Contributions of the Canton of Ticino

Reduction of capital tax for holding and/or intra-group financing companies
Paolo Pamini
Dr. oec., certified federal tax expert, National Councillor and member of the Economic and Tax Committee, Senior Manager PwC Lugano, Lecturer in Taxation at ETH Zurich

Valentina Franciolli
Lic. rer. pol., Senior Associate, PwC Lugano

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

Registration
https://bit.ly/webinar-21-04-2026

Registration deadline
Friday, April 17, 2026