The corporate tax systems of most European countries contain rules that provide some form of fiscal relief on income from participations. Under these rules, income, gains or losses from participations are often fully or partly disregarded. Switzerland also recognises participation relief in corporate taxation, yet its rules stand in sharp contrast to the ones commonly encountered, as they treat participations a priori as ordinary taxable assets. This provides both opportunities and pitfalls which taxpayers should be aware of.
        
        
        
            
                
    
        
        
            December 11 2017