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June 2018

In the previous tax notes, we pointed out the risk of a transfer stamp tax liability when arranging employee shares. In addition to the transfer stamp tax liability from the purchase and sale of securities, there is also a tax liability on premium payments for insurance policies if they are part of the portfolio of an insurer subject to federal supervision or of a domestic insurer under public law. The majority are probably aware of this. It is less well known that the tax liability ‘passes over’ to the domestic insurance holder, if the latter has taken out an insurance with a foreign insurer who is not subject to federal supervision (with exceptions for various types of insurance).

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