On 5 November 2019, the Finance Directorate and the Economic Directorate of the Canton of Zurich published a joint media release according to which there should be no tax obstacles in the event of an agreed change in the ownership structure of founding shareholders.
The media release concerns so-called "dynamic equity splits", i.e. founders agree among themselves to adjust their initially subscribed participation quotas during a certain period in order to do justice to the individual added value of each founder. The cantonal tax office takes a positive view of this objectively convincing method and will accept it. For reasons of legal certainty, it is recommended that such agreements be examined in advance.
The press release is available here.
