Christian Attenhofer

M.A. HSG Law & Economics,
Attorney at law, Certified Tax Expert
Partner

Christian Attenhofer has been advising companies and private individuals on intercantonal, national and international tax law for over ten years. His practice focuses on advising high net worth individuals, cross-border matters and tax-optimised succession planning, including issues relating to trust and foundation law. Christian Attenhofer also specialises in dispute prevention and tax litigation. He regularly represents clients in negotiations with tax authorities and in appeal and criminal tax proceedings before Swiss courts. He also lectures at EXPERTsuisse on family and inheritance law and is the author of numerous articles and commentaries on tax law.

Education

2020
Certified tax expert
2018
Lawyer
2014
MA HSG in Law & Economics

Experience

2026
Partner, PrimeTax AG
2024-2025
Senior Tax Manager, PrimeTax AG
2019-2024
Tax advisor with a leading tax boutique in Zurich, specializing in national and international tax for both individuals and corporations
As of 2023
Dozent im Steuerexperten-Lehrgang im Modul «Steuernahe Rechtslehre» (Familien- und Erbrecht)
2017-2018
Associate in a law firm with a focus on civil and criminal law
2015-2017
Trainee with a leading business law firm in Zurich, specializing in tax and corporate law
2014-2015
Staff member in the Legal Department of the Tax Administration of the Canton of Thurgau

Languages

German
English
French
Spanish

Publications

March 2026
Tax advice for individuals

Yes to Individual Taxation: New Rules for Married Couples

Mit der Abstimmung vom 8. März 2026 hat das Schweizer Stimmvolk Übergang zur Individualbesteuerung beschlossen. […]

February 2026
Konzerne und KMU

Greater clarity or increased complexity? New OECD criteria for home office permanent establishments

Home offices have become an integral part of today's working world. This new way of working is encountering pre-existing […]

February 2026
Konzerne und KMU

Overview of Tax Changes in 2026 and Outlook on Key Legislative Projects

As of January 1, 2026, various tax-related changes to laws and regulations will come into effect in Switzerland in […]

February 2026
Konzerne und KMU

2026 Interest Circulars of the STFA and Key Takeaways

On 29 and 30 January 2026, the Federal Tax Administration (FTA) issued new circulars on […]

January 2026

Analysis of Federal Supreme Court case law on international administrative assistance in tax matters from the first half of 2025

Christian Attenhofer, Analysis of Federal Court rulings on international administrative assistance in tax matters from the first half of […]

December 2025

Commentary on Swiss Tax Law, International Tax Law

Christian Attenhofer / Daniel Holenstein / René Matteotti, in: Zweifel/Beusch/Matteotti (Hrsg.), Kommentar zum Schweizerischen Steuerrecht, […]

October 2025
Tax advice for individuals

Abolition of the imputed rental value – What now?

The abolition of the imputed rental value marks a profound change in the Swiss tax system. With the elimination of […]

July 2025

Analysis of Federal Supreme Court case law on international administrative assistance in tax matters from the second half of 2024

René Matteotti / Christian Attenhofer, Analysis of Federal Court case law on international administrative assistance in tax matters from […]

May 2025
Tax advice for individuals

Tax-free capital gains or taxable income? What sharehold-ers need to be aware of

Tax-free capital gains are attractive to investors and entrepreneurs in Switzerland. But what applies to […]

January 2025

Analysis of the Federal Supreme Court's case law on international administrative assistance in tax matters from the first half of 2024

René Matteotti / Christian Attenhofer, Analysis of the case law of the Federal Supreme Court on international administrative assistance in tax matters from [...]

January 2025
Konzerne und KMU

Overview of the changes in tax legislation as of the year 2025

Various tax provisions came into force on 1 January 2025. These range from the introduction [...]

November 2024
Tax consulting for family offices

The UK definitely abolishes its non-dom regime – Switzerland offers a strong alternative

The UK non-dom regime is being abolished for good and will no longer be from April 6, 2025.[...]

August 2024
Konzerne und KMU

Swiss Federal Supreme Court “clarification” on the application of the SFTA safe harbor interest rates and its potential impact on practice

In its ruling 9C_690/2022 of July 17, 2024, a five-judge panel of the Swiss Federal Supreme Court[…]

June 2024
Konzerne und KMU

Extension of the international automatic exchange of in-formation to cryptoassets and salary data

Switzerland has committed to extending the international automatic exchange of information to crypto assets and salary data, [...]

May 2024

Tax Controversy 2024, Switzerland: Law & Practice

René Matteotti / Christian Attenhofer/Marija Ilic/Luka Schadegg, Tax Controversy 2024, Switzerland: Law & Practice, Chambers […]

May 2024

Tax Controversy 2024, Switzerland: Trends and Developments

René Matteotti / Christian Attenhofer, Tax Controversy 2024, Switzerland: Trends and Developments, Chambers Global Practice […]

April 2024

Transfer Pricing 2024, Switzerland: Law & Practice, Trends and Developments

René Matteotti / Monika Bieri / Daniel Schoenenberger / Caterina Colling-Russo/ Christian Attenhofer, Transfer Pricing […]

June 2023

Analysis of Federal Supreme Court case law on international administrative assistance in tax matters from the second half of 2023

René Matteotti / Christian Attenhofer, Analysis of the case law of the Federal Supreme Court on international administrative assistance in tax matters from [...]

January 2023

Commentary on the Aargau Tax Act, § 29a

Christian Attenhofer / Patrik Schwarb / Fabian Baumer, Klöti-Weber/Schudel/Schwarb (eds), Commentary on the Aargau Tax Act, § [...]

January 2023

Commentary on the Aargau Tax Act, § 29

Christian Attenhofer / Hans-Jörg Müllhaupt, Klöti-Weber/Schudel/Schwarb (Hrsg.), Kommentar zum Aargauer Steuergesetz, § 29 (Einkünfte aus […]

January 2023

Commentary on the Aargau Tax Act, § 27b

Christian Attenhofer, Klöti-Weber/Schudel/Schwarb (Hrsg.), Kommentar zum Aargauer Steuergesetz, § 27b (Teilbesteuerung im Geschäftsvermögen), 5. Aufl., […]

January 2023

Commentary on the Aargau Tax Act, §§ 5 and 6

Christian Attenhofer, Klöti-Weber/Schudel/Schwarb (Hrsg.), Kommentar zum Aargauer Steuergesetz, §§ 5 und 6 (Begriff der juristischen […]

January 2023

Switzerland: Law & Practice, Transfer Pricing 2023

René Matteotti / Hendrik Blankenstein / Caterina Colling-Russo / Monika Bieri / Christian Attenhofer, Switzerland: […]

December 2022

Analysis of the Federal Supreme Court's case law on international administrative assistance in tax matters from the second half of 2022

René Matteotti / Christian Attenhofer, Analysis of the case law of the Federal Supreme Court on international administrative assistance in tax matters from [...]

June 2022

Analysis of the Federal Supreme Court's rulings on international administrative assistance in tax matters from the first half of 2022

René Matteotti / Christian Attenhofer, Analysis of the case law of the Federal Supreme Court on international administrative assistance in tax matters from [...]

January 2022

Depreciation and value adjustments on participations

Oliver Jäggi / Christian Attenhofer, Impairments and Write-downs of Investments, ASA 90/8 (2021-2022), p. 459 [...]

January 2022

Transfer Pricing 2022, Switzerland: Law & Practice

René Matteotti / Hendrik Blankenstein / Monika Bieri / Christian Attenhofer, Transfer Pricing 2022, Switzerland: […]

January 2021

The right of the parties involved to fair VAT criminal proceedings

René Matteotti, The parties' right to fair VAT criminal proceedings, Jusletter, January 11, 2021 (co-worker [...]

January 2021

Transfer Pricing 2021, Switzerland: Law & Practice

René Matteotti / Hendrik Blakenstein / Monika Bieri / Christian Horni, Transfer Pricing 2021, Switzerland: […]

January 2020

§21 Immediate tax measures due to the COVID-19 pandemic

René Matteotti / Natalja Ezzaini / Christian Horni, §21 Tax law emergency measures due to the COVID-19 pandemic, in: [...]