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.

Discussion

Adam Warren Nov 12, 2013:
I suggest "Swiss financial-law transposition" adding a footnote in similar fashion to the condensed information I gave in an earlier entry here. I agree with Daryo, who has been the mainspring of the discussion, that there is no clear-cut rendering for this.
Daryo Nov 6, 2013:
a proper linguistic minefield ... I'm reluctant to propose any translation, as very often Swiss FR has its quirks and gives terms very particular local meanings, and you really have to get a full understanding of the subject matter to be sure. This ST is from a very specialised area of taxation, which makes it even trickier.
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 ...)

Davina Hepworth (asker) Nov 6, 2013:
Thank you, Ian.
Adam Warren Nov 6, 2013:
Transposition, from Daryo's reference, entails: - a change in nature from a private holding of capital into a corporate holding;
- 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.
Davina Hepworth (asker) Oct 29, 2013:
Thanks for your input, everyone. I think you are probably right. Does someone want to post an answer so that I will be able to award points later?
Nikki Scott-Despaigne Oct 29, 2013:
It strikes me that "transposition" will work universally here, whether in reference to the Netherlands, Switzerland or for understanding one or the other contexts for a UK target. Indeed, I think you have little choice.
Lorraine Dubuc Oct 29, 2013:
I do not understand the principle completely but found that transposition remains transposition in English in the finance sense. Link: http://www.finance.gov.ie/documents/legi/EUdirfor_transSep20...
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