Tax developments in Switzerland affecting trusts, indirect partial liquidations and tax holidays

This article examines three recent tax developments in Switzerland. The first is the new guideline on the taxation of trusts, which deals with the types of trusts and the taxation of the economic beneficiary (income tax, wealth or annual capital tax, and withholding tax). The second development is the new guideline on indirect partial liquidation, which reframes the scope of this anti-abuse measure by redefining key terms such as "qualifying investments", "distribution" and "reserves distributable under commercial law". The last part of the article updates the federal tax holiday regime, a major instrument of Swiss regional policy: the tax relief under the new law and the areas of economic renewal with respect to which the relief is available.