Overview of the tax law decisions of the Swiss Federal Supreme Court published between 21 - 27 March 2022:
- Ruling of 2 March 2022 (2C_135/2021): State and municipal taxes Basel-Stadt and direct federal tax 2017; The sole heir of a sole shareholder sold the company. Shortly afterwards, she assigned the purchase price claim to the sold AG in order to settle two debts. In the same year, the purchasing company sold its new subsidiary, whereby the last significant asset disappeared with the purchase price claim. In the present case, all conditions of the indirect partial liquidation are fulfilled and can be applied to the full liquidation (absorption merger). For the calculation, the distributable funds under commercial law apply, not those under tax law. The heiress actively participated in the liquidation by purchasing the art of the AG after its sale and assigning the purchase price claim to her. Dismissal of the complainant's appeal.
Non-occurrence:
Decisions are listed chronologically by publication date.
