Holding split
Company sales and succession arrangements are usually preceded by restructuring.
The Swiss Federal Tax Administration has simplified the holding company demerger, thus creating new possibilities for the tax-free sale of companies. In the following, we show you an example of a possible tax-neutral holding demerger. In any case, we recommend that you first discuss the specific facts and the associated tax consequences with the competent tax authorities in a binding tax ruling. Our experts will be happy to assist you in your specific case.
Initial situation
X intends to continue to operate the operations of subsidiaries A and B, but intends to
the sale of C AG. This operating company has a value of TCHF 10,000. For the tax-neutral demerger of a holding company, the resulting holding companies must fulfill the operating requirement either at the level of the holding company (so-called "holding operation") or at the level of the active company in which the holding company has an interest (so-called "operating operation").
Split
The tax-neutral demerger of X Holding AG is possible because both resulting holding companies fulfill the operating requirement, namely X H1AG as a holding company and X H2 AG by holding an operating participation with a minimum quota of 50%.
Sale
The shares in X H2 AG can be sold tax-free without observing a lock-up period.
Talk to us.
We'll show you the options for your initial situation.
Contact
Willy Ackermann willy.ackermann@artaris.ch