Oct 29, 2013 00:45
11 yrs ago
3 viewers *
French term
transposition
French to English
Bus/Financial
Law: Taxation & Customs
Swiss tax
Hello,
This is from a letter summarising information about the taxation (in Switzerland) of two people who are shareholders in a company. The company has been restructured. It was registered in Switzerland but the parent company is now Dutch, following this restructure.
I really don't understand what is meant by 'transposition'.
Thanks for your help.
Dans le contexte de la restructuration décrite, il n’y a pas d’état de fait de****** transposition****** du moment que les deux actionnaires minoritaires, seuls résidents de Suisse, n’auront pas le contrôle de la société mère après restructuration.
This is from a letter summarising information about the taxation (in Switzerland) of two people who are shareholders in a company. The company has been restructured. It was registered in Switzerland but the parent company is now Dutch, following this restructure.
I really don't understand what is meant by 'transposition'.
Thanks for your help.
Dans le contexte de la restructuration décrite, il n’y a pas d’état de fait de****** transposition****** du moment que les deux actionnaires minoritaires, seuls résidents de Suisse, n’auront pas le contrôle de la société mère après restructuration.
Discussion
I think they are using "transposition" in this ST in the sense of "changing the type of ownership" or s.t. along these lines, as the Swiss Tax system makes a distinction between "personal/private ownership" and "owned by a company". I have the nagging feeling that in FR FR it would be called s.t. totally else, so only refs from Switzerland are of any help, if you can find enough clues in them…
"transposition" (or the absence of it) has direct tax implications - the one and same amount of money may be taxed or not – depending on the Swiss taxman seeing or not any "transposition" happening in a transaction - really no connection with transposing EU directives into national laws of Member states. (or transposing a matrix or ...)
- acquisition of a controlling interest;
- various thresholds are also involved as well as (at least potentially) a capital gain on the transfer.
Pace Lorraine, this is entirely distinct from transposition of EU legislation into a Member State's law.
http://www.swisnot.ch/Fiscalite/liquidation-partielle-indire...