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Purchase of a Participation and Indirect Partial Liquidation

October 2007 - Tax & Private Client. Legal Developments by Walder Wyss Ltd.

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If an individual shareholder resident in Switzerland sells shares or otherforms of equity participations in a business which were the shareholder’sprivate assets (i.e., a passive investment) and after the sale the participations become part of the business assets of the purchaser, then the sellermay be required to pay income tax on the gain realized from the sale of theparticipations if assets are thereafter removed from the business.

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