On 31 January 2020, the Federal Tax Administration (FTA) published Circular Letters No. 22a "Partial Taxation of Income from Participations as Part of Private Assets and Restriction of Debt Interest Deduction" and No. 23a "Partial Taxation of Income from Participations as Part of Business Assets and Participations Declared as Business Assets".
With the entry into force of the Federal Law of 28 September 2018 on tax reform and AHV financing on 1 January 2020, the scope of partial taxation of income from investments of private assets as well as business assets was raised to a uniform 70 percent. As a result of this change in the law, the FTA has published new circulars to this effect.
The circular letters shall enter into force together with Article 18b para. 1 Article 20 para. 1bis DBG on 1 January 2020 and shall apply from the 2020 tax period. For matters up to 31 December 2019, circular letters Nos. 22 and 23 of 16 and 17 December 2008 continue to apply.
The circular letters are available here.
