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Swiss Federal Tax Administration Clarifies Treatment of Residual Tax on Distributions from Qualifying Participations for Top-Up Tax Purposes

|Approved Changes|Switzerland
Switzerland

The Swiss Federal Tax Administration has issued Communication-026-E-2025-e of 24 July 2025 - Top-up tax: consideration of residual tax on distributions from qualifying participations from 1 January 2024.

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Top-up tax: consideration of residual tax on distributions from qualifying participations from 1 January 2024

1. Background

The top-up tax (supplementary tax) is calculated based on …

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