¹ Coverage begins on the day on which the taxpayer takes residence in Switzerland or begins its stay in the tax law or on the day on which the taxpayer acquires a taxable item.

² The liability shall end on the date of death of the taxpayer, from his departure from Switzerland or on the day of the disappearance of the taxable element in Switzerland.

³ Coverage does not end in the event of a temporary transfer of a seat abroad or in the event of application of any other measure under federal legislation on the economic supply of the country.

¹ The incomes of the spouses living in a common household are added together, regardless of the matrimonial regime.

^1bis The income of registered partners living in a common household is added together. In this Act, registered partners have the same status as spouses. This principle also applies to the maintenance contributions during the registered partnership as well as for the maintenance contributions and the liquidation of the assets resulting from the suspension of the common life or the dissolution of the partnership. ²

² The income of children under parental authority is added to that of the holder of parental authority, with the exception of the income of the gainful occupation on which the children are taxed separately.

¹ Each heirs or partners adds to his or her own taxable items his or her share of the income from the hoot, the simple corporation, the partnership or the limited partnership.

² Each of the investors adds to its own taxable elements its share of collective investment income within the meaning of the Collective Investment Act of June 23, 2006 (CCPC) ² , with the exception of group investments that own directly owned buildings. ³

Foreign commercial companies and other foreign communities of persons without legal personality who are subject to tax on the basis of economic attachment may be taxed in accordance with the provisions applicable to persons Corporations.

¹ The heirs of a deceased taxpayer succeed him in his rights and obligations. They are jointly and severally liable for taxes owed by the deceased to the extent of their hereditary share, including hoary advances.

² The surviving spouse is liable to the extent of his or her hereditary share and, if he or she receives, as a result of his or her matrimonial regime, a share of the benefit or community in excess of his or her legal share under Swiss law, up to that Additional amount.

³ The surviving registered partner is liable to the extent of its hereditary share and the amount it receives under a property agreement within the meaning of s. 25, para. 1, of the Act of 18 June 2004 on partnership ¹ . ²

¹ Spouses living in common households are jointly and severally liable for the total amount of tax. However, each spouse answers the amount corresponding to his or her share of the total tax when one of them is insolvent. They are also jointly and severally liable for the share of the total tax levied on children's income.

² When the spouses do not live in a common household, the obligation to answer jointly and severally the total amount of the tax is extinguished for all the amounts of tax still owed.

³ Are jointly and severally liable with the taxpayer:

A.

Children placed under their parental authority, up to their share of total tax;

B.

The partners of a simple corporation, a partnership or a limited partnership who are domiciled in Switzerland, up to their social share, from the payment of the taxes owed by the partners domiciled abroad;

C.

The purchaser and the seller of a building situated in Switzerland up to a maximum of 3 % of the selling price, the payment of the taxes owed by the trader or the intermediary to which they have appealed, if he is not domiciled in Switzerland under the law Tax;

D.

Persons entrusted with the liquidation of undertakings or permanent establishments in Switzerland, of the alienation or realization of immovable property situated in Switzerland or of claims secured by such buildings, up to the net product, where the Taxpayer is not domiciled in Switzerland under the tax law.

⁴ The administrator of an estate and the executor act jointly and severally with the tax successors of the deceased, up to the amount that must be allocated to the payment of the tax according to the state of the Estate on day of death. They are released from any responsibility if they prove that they have taken all the care ordered by the circumstances.

¹ Natural persons have the right to be taxed on the basis of the expenditure instead of paying income tax if they meet the following conditions:

A.

Not have Swiss nationality;

B.

Be subject to unlimited title (s. 3) for the first time or after an absence of at least ten years;

C.

Not engage in a gainful occupation in Switzerland.

² Spouses living in common household must meet the conditions of para. 1.

³ The tax is calculated on the basis of the annual expenditure of the taxpayer and the persons for whom it is charged during the calculation period in Switzerland and abroad in order to ensure their lifestyle, but at least the highest of the The following amounts: ²

A.

400 000 francs;

B.

For taxpayer heads of household: seven times the annual rent or rental value within the meaning of s. 21, para. 1, let. B;

C.

For other taxpayers: three times the price of the annual allowance for housing and food at the place of residence within the meaning of s. 3;

D.

The sum of the following gross elements:

1.

Income from property wealth located in Switzerland,

2.

Income from movable objects located in Switzerland,

3.

Income from movable capital in Switzerland, including secured claims for immovable property,

4.

Income derived from copyright, patent and similar rights in Switzerland,

5.

Swiss pensions, annuities and pensions,

6.

Income for which the taxpayer requires partial or total relief from foreign taxes pursuant to a convention against double taxation concluded by Switzerland.

⁴ The tax is collected on the basis of the regular tax structure (s. 36). The reduction under s. 36, para. 2 ^Bis , 2 ^E Sentence, is not applicable. ³

⁵ If the income from a foreign state is exempt from it on the condition that Switzerland imposes them, alone or with other income, at the rate of total income, the tax is calculated not only on the basis of the income mentioned in para. 3, let. D, but also all elements of income derived from the source State which are attributed to Switzerland under the corresponding Convention against double taxation.

⁶ The Federal Department of Finance (DFF) ⁴ Adjusts the amount set out in para. 3, let. A, the Swiss consumer price index. Art. 39, para. 2, applies mutatis mutandis. ⁵

¹ Persons benefiting from tax exemptions under s. 2, para. 2, of the Act of 22 June 2007 on the Host State ¹ Are exempt from taxes to the extent provided under federal law. ²

² In the event of partial liability, s. 7, para. 1, is applicable.

Are exempt from tax:

A.

The makeshift revolutions of a succession, bequest, gift or liquidation of the matrimonial regime;

B.

Payments from private capital insurance that are eligible for purchase, with the exception of free-pass policies. Art. 20, para. 1, let. A, is reserved;

C.

The capital benefits paid by the employer or an institution of occupational foresight in the course of a change of employment, provided that the beneficiary reinvests them within the one-year period in an institution of occupational foresight or Uses them to acquire a free trade policy;

D.

Subsidies from public or private funds;

E.

Benefits paid under an obligation based on family law, with the exception of alimony and maintenance contributions referred to in s. 23, let. F;

F. ¹

The pay of the military service and the civil protection service allowance, as well as the pocket money of those who are subject to civil service;

F ^Bis . ²

The pay of militia firefighters, up to an annual amount of 5000 francs, for activities related to the performance of their essential tasks (exercises, picket services, courses, inspections and interventions, in particular for Rescue, firefighting, the fight against claims in general and the fight against claims caused by natural elements); the additional lump-sum allowances for executives, the additional function allowances, the Allowances for administrative work and benefits for benefits Provided voluntarily are not exempt;

G.

Remittances as compensation for moral harm;

H.

Income received under the federal legislation on supplementary benefits to the old age, survivors and disability insurance;

I. ³

Gains from gambling in gambling houses within the meaning of the law of 18 December 1998 on gambling houses ⁴ ;

J. ⁵

Lottery winnings or similar operations up to a maximum of 1000 francs.

¹ Are deducted from income:

A. ¹

6500 francs for each minor child or apprenticeship or study, of which the taxpayer insures the maintenance; where the parents are taxed separately, this deduction shall be allocated in half if they exercise the parental authority in common; and Do not claim a maintenance contribution for the child under s. 33, para. 1, let. C;

B. ²

6500 francs for each person totally or partly unable to engage in a gainful occupation, to which the taxpayer can provide, provided that his assistance reaches at least the amount of the deduction; this deduction is not For the spouse or for the children for whom the deduction is granted in accordance with the whistle. A;

C.

2600 francs for spouses living in common household. ³

² Social deductions are determined on the basis of the taxpayer's circumstances at the end of the tax period (s. 40) or subjugation. ⁴

³ In the case of partial liability, social deductions are granted proportionally.

¹ The effects of cold progress on the income tax of natural persons will be offset in full by an equivalent adjustment of the scales and deductions in francs on income. The amounts must be rounded to the top 100 or lower.

² The DFF annually adapts the scales and deductions to the Swiss consumer price index. The level of the index as of 30 June preceding the start of the fiscal period is decisive. Adaptation is excluded if the increase is negative. The adaptation which takes place after a negative increase is made on the basis of the last adapted scale. ¹

³ ... ²

¹ Corporations subject to tax are:

A.

Capital corporations (limited liability companies, limited partnerships, limited liability corporations) and cooperative corporations;

B.

Associations, foundations and other legal persons.

² Group investments that own real property within the meaning of s. 58 LPCC ¹ Are treated as other legal persons. Fixed-capital investment corporations within the meaning of section 110 CCPC are taxed as capital corporations. ²

³ Foreign corporations, as well as commercial corporations and foreign communities of persons taxable under s. 11, shall be assimilated to the Swiss legal persons whose legal form or structure is the most similar to them.

Legal persons are subject to taxation by virtue of their personal connection when they have their registered office or administration in Switzerland.

¹ Legal persons who have neither their registered office nor their effective administration in Switzerland are subject to tax on account of their economic attachment, where:

A.

They are associated with a company established in Switzerland;

B.

They operate a permanent establishment in Switzerland;

C.

They are the owners of a building situated in Switzerland or that they have on such immovable property rights of real enjoyment or of personal rights assimilable economically to real rights of enjoyment;

D.

They are holders or usufructuary of claims secured by real estate or collateral on immovable property situated in Switzerland;

E.

They trade real estate in Switzerland or act as intermediaries in real estate transactions.

² A permanent establishment is defined as any fixed place of business in which all or part of the business activity is carried out. In particular, branches, factories, workshops, sales outlets, permanent representations, mines and other places of exploitation of natural resources, as well as construction or construction sites, shall be regarded as permanent establishments. Montage of at least 12 months.

¹ Coverage based on personal attachment is unlimited; however, it does not extend to businesses, permanent establishments and buildings located outside Canada.

² The liability based on economic attachment is limited to the taxable profit in Switzerland within the meaning of Art. 51. ¹

³ In international relations, the extent of the liability of a business, permanent establishment or real property is defined in accordance with the rules of federal law relating to the prohibition of intercantonal double taxation. A Swiss company may compensate for losses of a permanent establishment abroad with profits made in Switzerland if the state in which the establishment is situated has not already taken account of such losses. If this establishment makes a profit in the following seven years, the tax will be recovered during those years to the extent that the carry-over of losses is offset in the State or it is situated. Losses on buildings outside Canada will only be considered if a permanent establishment is operated in the country concerned. The provisions contained in the double taxation agreements are reserved. ²

⁴ Taxpayers who have their seats and their actual administration abroad owe tax on the profit they make in Switzerland. ³

¹ Coverage begins on the day of the foundation of the corporation, the installation of its registered office or its effective administration in Switzerland, or the day on which it acquires a taxable element.

² The liability shall end on the day of the closure of the winding-up of the legal person, on the day of the movement of its registered office or administration abroad, or on the day on which the taxable item in Switzerland disappears.

³ In the event of the transfer of the assets and liabilities of one legal person to another, the taxes owed by the recovery legal person must be paid by the reprising legal person.

⁴ The temporary transfer of headquarters abroad, as well as all other measures within the meaning of the federal legislation on the economic supply of the country, are not equated with the end of subjugation.

¹ When the liability of a legal person ends, the persons responsible for its administration and liquidation shall jointly and severally be liable for the taxes it owes, to the extent of the proceeds of the liquidation or, if the legal person Transfers its headquarters or the place of its actual administration abroad, to the extent of the net capital of the legal person. They are released from any responsibility if they prove that they have taken all the care ordered by the circumstances.

² The following are jointly and severally liable for the taxes owed by a legal person subject to tax on account of economic attachment, up to the net proceeds realised, the persons charged:

A.

The liquidation of a business or permanent establishment in Switzerland,

B.

The alienation or realization of a building located in Switzerland or of claims secured by such a building.

³ Where a legal person who has neither his seat nor his effective administration in Switzerland acts as an intermediary in an operation on a building located in Switzerland, the purchasers and sellers of the building shall be jointly and severally liable to Competition of 3 % of the purchase price, of the taxes owed by that legal person because of its intermediary activity.

⁴ Members of commercial companies and other communities of persons of foreign law without legal personality are jointly and severally liable for the taxes owed by these companies and communities.

Are exempt from tax:

A.

Confederation and its institutions;

B.

The cantons and their establishments;

C.

Municipalities, parishes and other territorial authorities of the cantons, as well as their establishments;

D. ¹

The transport and infrastructure undertakings holding a grant from the Confederation who receive compensation for that activity or who must, as a result of their concession, maintain a service of national importance throughout the year; Gains which are derived from an activity subject to concession and are freely available are also exempt from tax; the related holdings and land which do not have a necessary relationship with the activity subject to concession are However excluded from this exemption;

E.

The institutions of professional foresight of undertakings having their domicile, their seat or a permanent establishment in Switzerland and of undertakings which have close links with them, provided that the resources of those institutions are affected In the long term and exclusively for the benefit of staff;

F.

The indigenous social insurance and compensation funds, including unemployment insurance, sickness, old-age, invalidity and survivors' insurance funds, with the exception of insurance companies;

G.

Legal persons who pursue public service or public utility purposes, on the profit exclusively and irrevocably assigned to those purposes. ² Economic goals cannot in principle be considered to be in the public interest. The acquisition and administration of significant capital interests to undertakings is of public interest where the interest in the maintenance of the undertaking occupies a subordinate position in relation to the purpose of public utility and Leadership activities are not carried out;

H. ³

Legal persons who pursue, on a national basis, cultural goals, on the profit exclusively and irrevocably allocated to those purposes;

I. ⁴

Foreign states, on their Swiss buildings exclusively for the direct use of their diplomatic and consular representations, as well as the institutional beneficiaries of tax exemptions referred to in Art. 2, para. 1, of the Act of 22 June 2007 on the Host State ⁵ , for the buildings owned and occupied by their services;

J. ⁶

Collective investments that have direct ownership, to the extent that investors are exclusively professional welfare institutions within the meaning of the let. E or funds that are indigenous to social insurance and compensation within the meaning of the let. F, which are exempt from tax.

¹ The DFF conducts surveillance on behalf of the Confederation (art. 2).

² THE AFC ¹ Ensures the uniform application of this Act. It lays down the implementing provisions to ensure correct and uniform taxation and collection of direct federal tax. It may prescribe the use of specified formulae.

³ The Federal Court of Appeal is the Federal Court of Appeal.

⁴ ... ²

¹ In particular, the AFC may:

A.

Carry out checks with the cantonal taxation and collection authorities and consult the tax files of the cantons and municipalities;

B.

Be represented in the deliberations of the taxation authorities and submit proposals;

C.

Order measures of education, in particular cases, or, where appropriate, take them on its own initiative;

D.

To request, in particular cases, that the taxation or the decision on complaint be notified to it as well;

E. ¹

Require notification of decisions, claims decisions, and appeals decisions relating to applications for the remission of direct federal tax.

² If it appears that a canton does not have enough or inadequate taxation, the DFF can take the necessary measures on a proposal from the AFC. In presenting its proposal, the AFC requires the Township to interrupt the notification of taxations.

¹ Any person who is called upon to make a decision or to participate decisively in the development of a decision or delivery under this Act is required to recuse himself:

A.

Whether it has a personal interest in the business;

B. ¹

If it is the spouse or registered partner of a party or leads a life of a couple with it;

B ^Bis . ² Whether it is a relative or an ally of a party in direct or collateral line up to the third degree;

C.

If it represents a party or acted for a party in the same case;

D.

If, for other reasons, it could have a preconceived opinion in the case.

² The challenge may be requested by any person participating in the proceedings.

³ Disputes concerning recusal shall be decided by an authority designated by the cantonal law if it is a cantonal civil servant and by the DFF if it is a federal official. The appeal is reserved in both cases.

¹ Persons responsible for the application of this Law or who cooperate in this Law shall keep secret the facts of which they are aware in the exercise of their function, as well as on the deliberations of the authorities and shall refuse to Consultation of tax files.

² Information may be disclosed to the extent that a legal basis of federal law expressly provides for it.

¹ The authorities responsible for the application of this Law shall provide mutual assistance in the performance of their tasks; they shall communicate free of charge to the tax authorities of the Confederation, the cantons, districts, circles and Any useful information and, at their request, allow them to consult tax files. The facts established by the authorities or brought to their knowledge pursuant to this provision shall be protected by tax secrecy, in accordance with Art. 110.

² If, for a taxation, the cantonal share is to be distributed among several cantons, the competent tax authority shall inform the cantonal authorities concerned.

¹ The authorities of the Confederation, the cantons, the districts, the circles and the municipalities shall, upon request, communicate any information necessary for the application of this Law to the authorities responsible for its execution. They may spontaneously report cases that may have been subject to incomplete taxation.

² The bodies of the communities and institutions to which the tasks of a public authority have been delegated shall be assimilated, as regards the duty to cooperate, to the authorities referred to in para. 1.

³ The bodies of Swiss Post and public credit institutions are free from the obligation to provide information and information on the facts on which they must keep the secret under special legal provisions. ¹

¹ The AFC manages an information system for the performance of its tasks under this Act. It may contain sensitive data relating to important administrative or criminal sanctions in the field of taxation.

^1bis The AFC and the authorities referred to in Art. 111 are entitled to systematically use the insured number AVS for the performance of their legal duties, in accordance with the law of 20 December 1946 on the old-age and survivors' insurance (LAVS) ² . ³

² The AFC and the authorities referred to in Art. 111 exchange data that can be useful in performing their tasks. The authorities cited in art. 112 shall communicate to the authorities responsible for the execution of this Law the data which may be important for its execution.

³ Data are reported in species cases or in lists, or on electronic data carriers. They may also be made available through an appeal process. This administrative assistance is free of charge.

⁴ Communication of all data that can be used for taxation and collection of taxes is mandatory, including:

A.

Identity;

B.

The civil status, the place of residence or residence, the residence permit and the gainful occupation;

C.

Legal operations;

D.

The benefits of public authorities.

⁵ Personal data and equipment used, such as data carriers, computer programs and documentation relating to these programs, must be protected from unauthorized manipulation, modification or destruction And flight.

⁶ The Federal Council may lay down implementing provisions relating in particular to the organisation and management of the information system, the categories of data to be seized, the access to data and the processing authorisations, the duration of the Retention, archiving and destruction of data.

⁷ The Federal Council definitively decides on disputes between the Federal Offices concerning the communication of data. In other cases, the Federal Court decides in accordance with s. 120 of the Act of 17 June 2005 on the Federal Court ⁴ . ⁵

¹ Spouses living in a common household exercise the rights and obligations under this Act in a joint manner.

² The tax return must bear both signatures. When the declaration is signed only by one of the spouses, a time limit is given to the spouse who has not signed. If the time limit expires without having been used, the contractual representation between spouses is assumed to be established.

³ In order for appeals and other writings to be deemed to be introduced in good time, it is sufficient that one of the spouses has acted within the time limit.

⁴ Any communication that the tax authority sends to married taxpayers who live in a common household is addressed to the spouses jointly.

¹ The taxpayer has the right to consult the documents in the file that he or she has produced or signed. Spouses who have to be taxed jointly have a reciprocal right of consultation.

² The taxpayer may become aware of the other documents once the facts have been established and provided that no public or private interest is in conflict with them.

³ Where an authority denies the taxpayer the right to consult a part of the case, it may rely on that document only to the detriment of the taxpayer if it has informed the taxpayer, orally or in writing, of the essential content of the case. The room and that it has the surplus allowed to express itself and to provide its own means of proof.

⁴ The authority which denies the taxpayer the right to consult its file confirms, at the request of the taxpayer, its refusal by a decision subject to appeal.

The taxpayer's offers of evidence must be accepted, provided that they are appropriate to establish facts relevant to taxation.

¹ Decisions and decisions shall be notified to the taxpayer in writing and shall indicate the legal remedies.

² Where the taxpayer has no known domicile or is abroad, without having a representative in Switzerland, the decisions and decisions may be validly notified to it by publication in the Official Gazette of the canton.

¹ The taxpayer may be represented contractually before the authorities responsible for the application of this Law, insofar as his or her personal cooperation is not necessary.

² Any person exercising civil rights and enjoying his civil rights may validly represent the taxpayer. The authority may require the representative to justify its representation by producing a written power of attorney.

³ Where spouses living in common household have not mandated a common representative or have not jointly appointed a person authorized to receive the mail, every notification must be addressed to both spouses jointly.

⁴ Notifications must be sent to each spouse when they live apart from fact or law.

The tax authorities may require that the taxpayer who has his or her domicile or seat abroad designate a representative in Switzerland.

¹ The time limits laid down in this Law shall not be extended.

² The time limits set by the authority may be extended if there are serious grounds and the request for an extension is made before the expiry of these time limits.

¹ The right to tax is prescribed five years from the end of the fiscal period. Art. 152 and 184 are reserved.

² The prescription does not run or is suspended:

A.

During the complaint, appeal or review procedures;

B.

As long as the claim for tax is secured by security rights or the recovery is deferred;

C.

As long as the taxpayer or a person jointly and severally liable with the taxpayer for the payment of the tax does not have a domicile in Switzerland or is not in Switzerland.

³ A new limitation period begins to run:

A.

Where the authority takes a measure to fix or enforce the claim for tax and informs the taxpayer or a person jointly and severally liable with it of the payment of the tax;

B.

Where the taxpayer or a person who is jointly and severally liable with the taxpayer specifically recognizes the tax debt;

C.

When an application for remission of tax is filed;

D.

When a criminal prosecution is then introduced by subtracting taxes or taxes.

⁴ The requirement of the right to tax is acquired in all cases 15 years after the end of the fiscal period.

¹ The tax claims shall be subject to five years from the entry into force of the taxation.

² For suspension and interruption of the requirement, s. 120, para. 2 and 3 shall apply mutatis mutandis.

³ The limitation period shall be acquired in all cases ten years from the end of the year in which the taxation is entered into force.

¹ Taxation authorities establish and maintain a register of presumptive taxpayers.

² The competent authorities of the cantons and municipalities shall communicate to the authorities responsible for the application of this Law all relevant information which emerges from their registers of control.

³ For preparatory work, the taxation authorities may require the cooperation of the municipal authorities or bodies specially entrusted with such work.

¹ The taxing authority monitors the tax return and carries out the necessary investigations.

² It carries out ex officio taxation on the basis of a conscientious assessment if, despite summons, the taxpayer has not fulfilled its procedural obligations or the taxable items cannot be determined with all the precision In the absence of sufficient data. It can take into account the experimental coefficients, the evolution of wealth and the taxpayer's lifestyle.

¹ The taxing authority shall fix, in the taxation decision, the taxable items (taxable income, taxable net income), the rate and the amount of tax. In addition, it indicates to the capital corporations and the cooperative corporations the amount of own capital established after the taxation of the income tax and the taking into account of the profit distributions. ¹

² It shall inform the taxpayer of the changes made to its declaration at the latest in the notification of the taxation decision.

³ The taxation decision must also be notified to the cantonal administration of direct federal tax and to the AFC where they have intervened in the taxation procedure or have requested that the decision be communicated to them (art. 103, para. 1, let. D, and 104, para. 1).

¹ A taxpayer may make a written complaint to the taxation authority against the taxation decision within 30 days after the taxpayer's notification.

² The complaint lodged against a previously reasoned taxation decision may be regarded as an appeal and transmitted to the cantonal tax appeals committee if the taxpayer and the other entitled persons consent to it (Art. 103, para. 1, let. B, and 104, para. 1).

³ A taxpayer who has been taxed ex officio may file a claim against that taxation solely on the ground that it is manifestly inaccurate. The claim must be substantiated and indicate, where appropriate, the means of proof.

¹ The period begins to run the day after the notification. It is considered to be respected if the claim has been remitted to the taxation authority, to a Swiss post office or to a Swiss diplomatic or consular representation abroad on the last working day of the period at the latest. When the last day of the period falls on a Saturday, a Sunday or an official holiday, the period expires on the first working day following.

² The complaint to an incompetent authority shall be forwarded without delay to the competent taxation authority. The claim period is considered to be respected where the claim has been given to an incompetent authority or to a Swiss post office on the last working day of the period at the latest.

³ After the 30-day period, a complaint is admissible only if the taxpayer establishes that, as a result of military service, civil service, sickness, absence from the country or for other serious grounds, he was prevented from submitting his claim In a timely manner and filed within 30 days after the end of the impediment. ¹

¹ The taxation authority, the cantonal administration of direct federal tax and the AFC have the same powers in the claim procedure as in the taxation procedure.

² No further action is taken to withdraw the claim if it appears, in the light of the circumstances, that the taxation was incorrect. In addition, the complaint procedure cannot be closed without the consent of all the tax authorities that have intervened in the taxation procedure.

¹ The taxation authority shall, after investigation, take a decision on the complaint. It can redetermine all the elements of the tax and, after hearing the taxpayer, change the taxation even to the disadvantage of the taxpayer.

² The decision shall be reasoned and notified to the taxpayer and to the cantonal administration of direct federal tax. It shall also be communicated to the AFC when it has intervened in the taxation or has requested that the decision on the complaint be communicated to it (Art. 103, para. 1).

³ The claim procedure is free of charge. However, s. 123, para. 2, last sentence shall apply mutatis mutandis.

¹ The taxpayer may object to the decision on the claim of the taxation authority by addressing, within 30 days of the notification of the contested decision, an independent review panel of the tax authorities. ¹ Art. 132, para. 2, is reserved.

² It shall indicate, in the notice of appeal, its conclusions and the facts on which they are based, as well as the means of evidence; the documents serving the evidence must be attached to the act or described precisely. Where the appeal is incomplete, a fair period of time is allocated to the taxpayer to remedy the appeal, subject to inadmissibility.

³ Any error in the contested decision and any procedural defect constitute grounds for appeal.

⁴ Art. 133 shall apply mutatis mutandis.

¹ The cantonal administration of direct federal tax and the AFC may appeal to the cantonal board of appeal against any taxation decision or decision on the claim of the taxation authority.

² The appeal period is:

A.

30 days from the date of notification in the case where the taxation decision or the decision on a complaint has been notified to the administering authority;

B.

60 days from the date of notification to the taxpayer in other cases.

¹ The cantonal appeal board invites the taxing authority to determine and send it to the Commission. It also requires advance notice from the cantonal administration of direct federal tax and the AFC.

² When the appeal is brought by the cantonal federal tax administration or the AFC, the cantonal appeal board invites the taxpayer to speak.

³ Where the opinion submitted by the authority in response to the taxpayer's appeal contains new arguments of fact or law, the Cantonal Board of Appeal shall invite the taxpayer to also comment on them.

⁴ In the appeal procedure, the cantonal appeal board has the same powers as the taxing authority in the taxation procedure.

⁵ The taxpayer's right to consult the file is governed by s. 114.

¹ The cantonal appeal board shall take its decision after hearing the appeal. After hearing the taxpayer, the taxpayer may also change the taxation at the taxpayer's disadvantage.

² It shall communicate its reasoned decision in writing to the taxpayer and to the authorities who intervened in the proceedings.

¹ The costs of the proceedings before the cantonal appeal board shall be borne by the unsuccessful party; where the appeal is partially allowed, they shall be prorated.

² All or part of the costs shall be borne by the successful applicant, when, by complying with his or her obligations, he may have obtained satisfaction in the tax or claim procedure already or where he has Hindered the instruction of the cantonal appeal board by its dilatory attitude.

³ The Cantonal Board of Appeal may waive fees where special circumstances warrant.

⁴ For the allocation of costs, art. 64, para. 1 to 3, of the Federal Act of 20 December 1968 on administrative procedure ¹ Applies by analogy.

⁵ The amount of the costs of the proceedings before the cantonal appeal board shall be determined by the cantonal legislation.

¹ To the extent that the cantonal law provides for it, the decision on appeal may still be brought before another cantonal body, independent of the administration.

² Art. 140 to 144 shall apply mutatis mutandis.

The decision of the cantonal appeal board or the decision of another cantonal appeal body within the meaning of Art. 145 may be appealed to the Federal Court. The cantonal administration of direct federal tax also has the right to use it.

¹ A decision or decision entered into force may be revised in favour of the taxpayer, at the request of the taxpayer or ex officio:

A.

When significant facts or conclusive evidence are found;

B.

Where the authority that has ruled has failed to take into account important facts or conclusive evidence that it knew or ought to know or otherwise violated any of the essential procedural rules;

C.

When a crime or an offence has influenced the decision or delivery.

² The revision shall be excluded where the applicant has relied on grounds which he may have already been able to assert in the ordinary procedure if he had exercised all the due diligence that could reasonably be required of him.

³ The revision of the Federal Court's judgments is governed by the Act of 17 June 2005 on the Federal Court ¹ . ²

The application for review must be filed within 90 days following the discovery of the reason for the review, but no later than 10 years after notification of the decision or delivery.

¹ The review of a decision or delivery is within the jurisdiction of the authority that issued the decision or delivery.

² If there is a reason for review, the authority cancels the previous decision or pronouncet and decides again.

³ Rejection of the application for review and the new decision or delivery may be subject to the same legal remedies as the previous decision or delivery.

⁴ In addition, the provisions relating to the procedure followed in the previous decision or decision shall apply.

¹ Errors in calculation and transcription contained in a decision or in force may, upon request or ex officio, be corrected within five years of the notification by the authority which committed them.

² The correction of the error or the refusal to do so may be attacked by the same legal channels as the decision or delivery.

¹ Where evidence or facts previously unknown to the tax authority enable it to establish that taxation has not been carried out, where it should have been, or that a taxation entered into force is incomplete or that taxation not Made or incomplete is due to a crime or an offence committed against the tax authority, the tax authority shall carry out a reminder of the tax which has not been collected, including interest.

² Where the taxpayer has filed a complete and accurate return on income, capital and net income, determined the taxpayer's own capital in an appropriate manner and the tax authority has accepted the assessment, any tax reminder is Excluded, even if the assessment was insufficient. ²

¹ The right to introduce a recall procedure shall lapse 10 years after the end of the tax period for which the taxation has not been carried out, where it should have been, or for which the taxation entered into force was incomplete.

² The introduction of a procedure for the subsequent criminal prosecution of tax evasion or tax evasion also leads to the commencement of the recall procedure.

³ The right to recall tax is extinguished 15 years after the end of the fiscal period to which it relates.

¹ The taxpayer is notified in writing of the commencement of a recall procedure.

^1bis If, at the time of commencement of the recall procedure, no criminal procedure for subtraction of tax is not open and cannot be excluded from the outset, the taxpayer will be notified that a criminal procedure for subtraction of tax May later be opened against him. ¹

² Where the death of the taxpayer, the procedure has not yet been introduced or has not been completed, it may be opened or continued against the heirs.

³ Moreover, the provisions concerning general principles of procedure, the procedures for taxation and appeals shall apply mutatis mutandis.

¹ Each heirs is entitled, independently of the others, to the simplified tax reminder on the elements of the wealth and income subtracted by the deceased, provided that:

A.

That no tax authority is aware of the exemption;

B.

It collaborates without reservation with the administration to determine the elements of wealth and income subtracted;

C.

Endeavour to pay the tax reminder due.

² The tax reminder is calculated on the three tax periods preceding the year of death in accordance with the provisions on ordinary taxation and collected with the interest of moratoria.

³ The simplified reminder shall be excluded in the event of the official liquidation of the estate or liquidation of the estate according to the rules of the bankruptcy.

⁴ The executor or administrator of the estate may also request the simplified reminder.

¹ A formal inventory is established within two weeks of the taxpayer's death.

² No inventory is established, where circumstances make it possible to assume that the deceased did not leave a fortune.

¹ The inventory includes the deceased's fortune, that of his spouse living in common household with him and that of minor children under his parental authority, estimated on the day of death.

² The facts of importance for taxation shall be established and referred to in the inventory.

¹ The heirs and the persons who administer or have custody of the estate cannot dispose of them, before the inventory, without the consent of the competent authority.

² In order to ensure the accuracy of the inventory, the competent authority may order the immediate sealing of the seals.

¹ The heirs, legal representatives of heirs, the administrator of the estate and the executor of the estate must:

A.

Provide, in accordance with the truth, all information relevant to the determination of the taxable elements that belonged to the deceased;

B.

Produce all books, supporting documents, statements of status or other documents to determine the status of the estate;

C.

Provide access to all premises and furniture available to the deceased.

² The heirs and legal representatives of heirs who shared with the deceased or had the custody or administration of some of his property must also allow the visit of their own premises and furniture.

³ The heirs, the legal representatives of the heirs, the administrator of the estate or the executor who, after the establishment of the inventory, learn the existence of estate properties not included in the inventory, must inform The competent authority within ten days.

⁴ At least one of the heirs having the exercise of civil rights, as well as the legal representative of the minor or sub-curatorate heirs, or the representative on grounds of incapacity, shall attend the inventory. ¹

¹ Third parties who had the custody or administration of property of the deceased or against whom the deceased had substantial rights or claims in money are required to give to the heir who so requests, for the authority of the authority Competent, all written information relating thereto.

² If there are serious grounds for the third party to fulfil the obligation to provide information, the third party may provide the requested information directly to the competent authority.

³ In addition, s. 127 and 128 shall apply mutatis mutandis.

¹ The inventory shall be drawn up and the seals affixed by the competent cantonal authority of the place where, in the light of the tax law, the deceased had his last domicile or was in residence at the time of his death or the place where he had elements Taxable.

² Where the inventory is ordered by the adult protection authority or the judge, a copy shall be communicated to the competent authority. ¹ The latter may take up this inventory as is, or, if necessary, order that it be completed.

³ The civil service offices shall report without delay any death to the competent tax authority of the place where, under the tax law, the deceased had his last domicile or was in residence at the time of his death (art. 3).

The tax is collected by the canton in which the taxation was carried out.

¹ As a general rule, the tax has expired at the end of the DFF (term general term). It may be collected by instalments.

² For taxes owing by taxpayers for which the fiscal year does not coincide with the calendar year (s. 79, para. 2), the tax authority may fix special term terms.

³ The following shall be due to the notification of the taxation decision:

A.

The tax on capital benefits arising from foresight (art. 38);

B. ¹

...

C.

Tax reminders (s. 151).

⁴ The tax is payable in all cases:

A.

The day on which the taxpayer intends to leave the country on a long-term basis makes arrangements for his departure;

B.

When requisitioning the cancellation of the business register of a legal person subject to tax;

C.

As soon as a foreign taxpayer ceases to have a business or an interest in a Swiss business, a permanent establishment situated in Switzerland, a building situated in Switzerland or a claim secured by a building located in Switzerland (art. 4, 5 and 51);

D.

When the taxpayer's bankruptcy is opened;

E.

At the taxpayer's death.

⁵ The prescribed term is maintained, even if the taxpayer has received, on that date, only a preliminary tax calculation or has filed a claim or appeal against taxation.

¹ Direct federal tax is levied on the basis of taxation. Where the taxation is not yet completed at the end of the term, the tax is collected on an interim basis. It is fixed on the basis of the declaration or on the basis of the preceding taxation or on an estimate of the amount due.

² Taxes collected on an interim basis are charged against taxes owing on the basis of final taxation.

³ If the amounts collected are insufficient, the difference is required; the overpaid amounts are returned. The DFF lays down the conditions to which these amounts are of interest.

¹ Taxes must be paid within 30 days of the due date. The collection of taxes by instalments is reserved (art. 161, para. 1).

² The DFF provides a remunerative interest in payments made by the taxpayer before the deadline.

³ The cantons shall indicate by official publication the general terms of maturity and payment as well as the cantonal cash-out services.

¹ The debtor of the tax who has not paid the amounts due within the time limits must pay a moratorium fixed by the DFF.

² If, at the end of the day, the tax debtor has not yet received notification of the calculation of the tax, and he is not responsible for the delay, the interest does not begin to run until 30 days after the notification.

¹ Where the tax is not subsequently paid out of the summons, proceedings shall be instituted against the debtor.

² If the debtor of the tax does not have a domicile in Switzerland or a receiver has been ordered on property belonging to it, the prosecution procedure may be introduced without prior warning.

³ In the proceedings for prosecution, decisions and decisions of taxation issued by the authorities responsible for the application of this Law, which have entered into force, shall have the same effect as a binding judgment.

⁴ It is not necessary to file tax claims in official inventories and calls to creditors.

¹ If the payment, within the prescribed time, of the tax, interest and costs and the subsequent fine imposed by a contravention were to have very harsh consequences for the debtor, the collecting authority may extend the time limit for the Payment or authorizing a staggered payment. It may waive the interest due on the amounts for which the payment is deferred.

² Payment facilities may be subject to obtaining appropriate guarantees.

³ The payment facilities which have been granted shall be revoked where the circumstances justifying their grant no longer exist or the conditions to which they are subordinated are not fulfilled.

¹ If, for the taxpayer who has fallen into destitution, the payment of the tax, interest or fine imposed subsequently on a ticket has very harsh consequences, the amounts owing may, on request, be subject to a total remission or Partial.

² The purpose of the tax remission is to provide a lasting solution to the taxpayer's economic situation. It must benefit the taxpayer itself and not its creditors.

³ Fines and reminders of tax may be awarded only in exceptional cases which are particularly well-founded.

⁴ The surrender authority shall only enter into the application for surrender before the notification of the command to pay (art. 38, para. 2, of the PMQ of 11 April 1889 on the continuation of debts and the bankruptcy; LP ² ).

⁵ In cases of taxation at source, only the taxpayer or a contractual representative designated by the taxpayer may file an application for remission.

The remission of tax may be in part or in whole refused, in particular where the taxpayer:

A.

Has failed seriously or repeatedly in its duties in the taxation procedure, so that the assessment of its financial situation for the tax period concerned is no longer possible;

B.

Did not create reserves despite the availability of resources from the tax period to which the claim for remission relates;

C.

Did not make payments despite the availability of means at the due date of the tax debt;

D.

Owes its incapacity to contribute to the voluntary renunciation of income or to a fortune without any significant reason, an exaggerated standard of living or any other reckless or gravely negligent behaviour;

E.

Preferred other creditors during the period assessed.

¹ The cantons determine the competent cantonal authority for the remission of direct federal tax (remission authority).

² They set out the procedure to the extent that it is not regulated by federal law. This provision also applies to tax remittance procedures at source.

The request for surrender shall be made in writing, shall be reasoned and shall be accompanied by the necessary evidence. It describes the deprivation as a result of which the payment of tax, interest or fine would have very harsh consequences.

¹ The rights and obligations of the applicant shall be governed by this Law. The applicant is required to provide full information to the Remission Authority on its economic situation.

² If, despite reminders and summons, the applicant refuses to provide the necessary assistance that the Remission Authority can expect from him, the latter may decide not to enter into the matter on his application.

³ The administrative procedure and the complaint procedure before the discount authority are free of charge. The costs may, however, be borne by the applicant, in whole or in part, if his application is manifestly unfounded.

The Remission Authority shall have all the means of investigation provided for in this Law.

By way of order, the DFF specifies in particular the conditions of grant, the grounds for refusal and the procedure for the remission of tax.

¹ The applicant has the same legal remedies against the decision concerning the surrender of direct federal tax only against the decision on the remission of the cantonal income tax and on the benefit.

² The AFC has the same legal remedies as the applicant.

³ The Remission Authority shall have the same legal remedies to appeal against a decision on an administrative appeal or a decision of an independent body of the administration which it has before it to appeal against the decision On appeal concerning the remission of the cantonal income tax and on the benefit.

⁴ Art. 132 to 135 and 140 to 145 are applicable by analogy.

⁵ Pursuant to the Act of 17 June 2005 on the Federal Court ² , the applicant, the surrender authority and the AFC may appeal to the Federal Court against the cantonal decision of last instance in the field of public law.

¹ The taxpayer may request the return of an amount of tax paid in error, if the taxpayer was not required to pay tax or was owed only in part.

² The tax amounts that are returned more than 30 days after their payment are paid interest as of the date of their payment at the rate set by the DFF.

³ The application for restitution must be addressed to the cantonal administration of direct federal tax within five years of the end of the calendar year in which the payment took place. Rejection of the application for restitution opens the same legal remedies as a taxation decision (Art. 132). The right to restitution shall lapse 10 years after the end of the year in which the payment took place.

¹ If the taxpayer does not have a domicile in Switzerland or the tax rights appear threatened, the cantonal administration of direct federal tax may require security rights at all times, even before the amount of tax is fixed by a decision Entry into force. The application for security shall indicate the amount to be guaranteed; it shall be immediately enforceable. In the prosecution procedure, it produces the same effects as a binding judgment.

² Security rights must be provided in cash, secure and negotiable securities, or in the form of a bank's bond.

³ The taxpayer may oppose the application for security rights by filing an appeal before the cantonal appeal board within 30 days of the notification. Art. 146 is applicable. ¹

⁴ The appeal against an application for security rights has no suspensive effect. ²

¹ The application for security is treated as a receiver order within the meaning of s. 274 LP ² The receiver shall be operated by the competent prosecution office.

² The opposition to the receiver order provided for in s. 278 LP is not admissible.

A legal person may be removed from the register of commerce only where the cantonal administration of direct federal tax communicates to the Office of the commercial register that the taxes owing are paid or that they have been the subject of security.

¹ Where a natural person or corporation liable to tax solely on account of a real estate component (s. 4, para. 1, let. C, and art. 51, para. 1, let. (c) alienates a building located in Switzerland, the purchaser can only be registered in the land register as an owner with the written agreement of the cantonal administration of the competent federal direct tax.

² The cantonal administration of direct federal income tax shall provide to the alienator, for the purpose of the land registry operator, a certificate confirming the agreement where the taxes related to the possession or disposition of the real property are paid or Secured by security rights where it is established that no tax is payable or that the alienator provides sufficient guarantees for the fulfilment of its tax obligations.

³ If the cantonal administration refuses to establish the certificate, an appeal may be lodged against that decision before the cantonal tax appeals committee.

Where a building in Switzerland is purchased or sold through a natural or legal person who has neither his domicile nor his seat, nor his effective administration in Switzerland, the cantonal administration of direct federal tax may require Sellers or purchasers the payment of 3 % of the purchase price in respect of security rights guaranteeing payment of the taxes due as a result of the intermediary activity.

¹ A fine shall be imposed on the person who, despite the summons, intentionally or negligently breaches an obligation under this Act or any action taken pursuant to this Act, including:

A.

By not filing a tax return or accompanying schedules,

B.

By failing to provide the certifications, information or information that it is required to provide,

C.

Failing to fulfil its obligations under an inventory procedure, in its capacity as heir or third party.

² The fine is not more than 1000 francs; it is not more than 10 000 francs in serious cases or in the event of a repeat offence.

¹ A taxpayer who, intentionally or negligently, ensures that a taxation is not carried out while it should be, or that a taxation entered into force is incomplete,

The person who, under the obligation to collect a tax at source, does not withhold or withhold tax from the source, whether intentionally or negligently,

The person who, intentionally or negligently, obtains an unlawful return of tax or an unjustified remission of tax,

Is liable to a fine.

² As a general rule, the fine is fixed to the amount of tax subtracted. If the fault is slight, the fine may be reduced to a third of that amount; if the fault is serious, it may at most be tripled.

³ When the taxpayer spontaneously denounces and for the first time a tax evasion, the criminal prosecution (spontaneous non-punishable denunciation) is renounced, provided that:

A.

That no tax authority is aware of it;

B.

It collaborates without reservation with the administration to determine the amount of the tax reminder;

C.

Endeavour to pay the tax reminder due. ¹

⁴ For any subsequent spontaneous denunciation, the fine shall be reduced to the fifth of the tax subtracted if the conditions laid down in para. 3 are completed. ²

¹ Anyone who tries to evade taxes will be fined.

² The fine is set at two-thirds of the penalty that would be imposed if the subtraction had been committed intentionally and consumed.

¹ The person who, intentionally, incites to a tax subtraction, assists, commits, or participates as a representative of the taxpayer, shall be liable to a fine fixed independently of the penalty incurred by the taxpayer; and It is jointly and severally liable for the tax subtracted. ¹

² The fine is not more than 10 000 francs; it is not more than 50 000 francs in serious cases or in the event of a repeat offence. ²

³ When a person within the meaning of s. 1 denounces spontaneously and for the first time and that the conditions laid down in Art. 175, para. 3, let. A and b are fulfilled, the criminal prosecution and joint and several liability shall be abolished. ³

¹ Whoever conceals or distracts estate assets of which he or she is required to announce the existence in the inventory procedure, in order to remove them from the inventory,

The person who incites or assists in such an act,

Be punished with a fine. ¹

² The fine is not more than 10 000 francs; it is not more than 50 000 francs in serious cases or in the event of a repeat offence.

³ An attempt to concede or entertain estate is also punishable. A lighter penalty than that incurred in the event of an offence may be imposed.

⁴ Where a person referred to in para. 1 is self-denouncing and for the first time it is renounced criminal prosecution for concealability or diversion of estate in the inventory procedure and for other offences committed under this procedure (spontaneous non-punishable denunciation), provided that:

A.

That no tax authority is aware of the offence;

B.

The data subject collaborates without reservation with the administration to correct the inventory. ²

A married taxpayer who lives in a common household with his or her spouse only answers the taxable items that are specific to the taxpayer. Art. 177 is reserved. The mere fact of countersigning the joint tax return does not constitute an offence within the meaning of s. 177.

¹ Where procedural obligations have been breached or a subtraction or attempt to subtract tax has been committed for the benefit of a legal person, the legal person shall be liable to a fine.

² Where a legal person has incited, assisted or participated in the exercise of his or her activity, subtracting by a third party, s. 177 is applicable to him by analogy.

³ The criminal prosecution of organs or representatives of the legal person under s. 177 is reserved.

⁴ The s. 1 to 3 shall apply mutatis mutandis to foreign corporations and institutions and to communities of foreign persons without legal personality.

¹ When a corporation subject to tax spontaneously denounces and for the first time a tax evasion in its commercial exploitation, it is renounced criminal prosecution (spontaneous non-punishable denunciation), provided that:

A.

That no tax authority is aware of it;

B.

The data subject collaborates without reservation with the administration to determine the amount of the tax reminder;

C.

Endeavour to pay the tax reminder due.

² Spontaneous non-punishable information may also be filed:

A.

After a change in the name or relocation of the registered office within the territory of Switzerland;

B.

After a transformation within the meaning of s. 53 to 68 of the Act of 3 October 2003 on Amalgamation (LFus) ² , by the new corporation, in respect of tax evactions committed prior to the conversion;

C.

After absorption (art. 3, para. 1, let. A, LFus) or a split (s. 29, let. B, LFus), by the remaining legal entity, in respect of tax subtractions committed prior to absorption or division.

³ Spontaneous non-punishable denunciation shall be lodged by the organs or representatives of the legal entity. The joint and several liability of these bodies or representatives shall be abolished and the criminal prosecution shall be renounced.

⁴ Where former members of the organs or former representatives of the legal entity have for the first time denounced a tax deduction for which no tax authority is aware, the criminal prosecution of the legal person shall be renounced; As well as all current and former members and representatives. Their joint and several liability is deleted.

⁵ For any subsequent spontaneous denunciation, the fine shall be reduced to the fifth of the tax subtracted when the conditions laid down in para. 1 are completed.

⁶ When a corporation ceases to be subject to tax in Switzerland, it can no longer file a spontaneous denunciation.

¹ Upon completion of the appraisal, the authority shall make a decision, which shall be notified in writing to the person concerned. ¹

² The cantonal decisions of the last instance may be appealed to the Federal Court in accordance with the Federal Court Act of 17 June 2005. ² The criminal route is excluded. ³

³ The provisions on general principles of procedure and procedures for taxation and appeals shall apply mutatis mutandis.

⁴ The canton refers to the prosecuting authorities for evading taxes and for breaches of procedural rules.

¹ The opening of a criminal procedure for the removal of tax shall be communicated in writing to the person concerned. The Commission is invited to comment on the grievances held against him and to inform him of his right to refuse to file and to cooperate. ¹

^1bis The evidence gathered in the context of the recall procedure may be used in the criminal procedure for tax evasion only if they have not been collected or subject to the threat of ex officio taxation (Art. 130, para. 2) with a reversal of the burden of proof within the meaning of s. 132, para. 3, or under threat of a fine in case of breach of a procedural obligation. ²

² The AFC may require the prosecution to subtract tax. ... ³

³ When the AFC has requested the prosecution for a subtraction or has participated in the proceedings, the decision on conviction or non-suit issued by the cantonal authority shall also be notified to it.

⁴ The costs of special training measures (accounting expertise, expert reports, etc.) Are, in principle, the burden of the person convicted of evading charges; they may also be placed at the expense of the person who obtained a non-suit when, by reason of its wrongful conduct, it has brought the tax authority to Initiate criminal prosecution or have significantly complicated or slowed the investigation.

¹ The criminal prosecution is prescribed:

A.

In the case of a breach of the procedural obligations by two years and in the event of an attempt to subtract tax by four years from the final closure of the proceedings in which the breach of the procedural obligations or the attempt Subtraction was committed;

B.

In the case of tax evasion, by ten years from the end of the tax period for which taxation has not been carried out or has been incomplete, or for which tax at source has not been collected in accordance with the law, Or ten years from the end of the calendar year in which an unlawful return of tax or an unjustified tax refund has been obtained, or goods have been concealed or distracted in the inventory procedure.

² The limitation period shall be interrupted by any procedure for the prosecution of the taxpayer or of one of the persons referred to in s. 177 ¹ The interruption is effective against both the taxpayer and those other persons. A new period of time starts at each interruption; however, the limitation period cannot be extended by more than half of its initial duration.

¹ The fines and costs resulting from the criminal proceedings are levied according to the provisions of the art. 160 and 163 to 172.

² For the limitation period, s. 121 shall apply mutatis mutandis.

¹ Annuities and capital benefits arising from occupational foresight, which began to run or become due before 1 ^Er January 1987, or which were based on a pre-need report that already existed as of 31 December 1986 and start to run or become due before 1 ^Er January 2002, are taxable as follows:

A.

Three fifths, if benefits (such as deposits, contributions, premiums) on which the taxpayer's claim is based were made exclusively by the taxpayer;

B.

Four fifths, if the benefits on which the taxpayer's claim is based were only partially made by the taxpayer, but that part form at least 20 % of the benefits;

C.

In other cases.

² The same applies to the taxpayer's benefits within the meaning of para. 1, let. A and b, the benefits of his or her family members; the same applies to third party benefits, if the taxpayer has acquired the right to insurance through devolution, bequest or donation.

The insured's contributions for the redemption of years of insurance are deductible, provided that the old-age benefits begin to accrue or become due after December 31, 2001.

¹ Return on Capital Insurance Under Art. 20, para. 1, let. A, which were concluded before 1 ^Er January 1994 remains exempt to the extent that, at the time the insured person is in receipt of the benefit, the contractual relationship lasted at least five years or that the insured person completed his or her 60 ^E Year.

² The returns to insurance under s. 20, para. 1, let. A, which have been concluded between 1 ^Er January 1994 and December 31, 1998, remain exempt if, when the insured receives the benefit, the contract has lasted at least five years and the insured person is 60 years of age. ²

Art. 20 A , para. 1, let. A, applies to taxations that are not yet enforceable in respect of income earned from the 2001 fiscal year.

The Reminder provisions of the former right apply to estates that were open prior to the effective date of the March 20, 2008 amendment.

The DFF adapts the scales and deductions for the fiscal year 2010 to the Swiss Consumer Price Index, provided that the present amendment was adopted at the 2009 summer session and the referendum period has expired Without the referendum being requested. Otherwise, the first adaptation will take place for the 2011 fiscal year.

For natural persons who are taxed on the basis of expenditure at the time of entry into force of the amendment of 28 September 2012, s. 14 is still applicable for five years.

¹ The cantonal surrender authority shall rule on applications for the remission of direct federal tax which, at the time of the entry into force of the amendment of this Law on 20 June 2014, are pending before the Federal Tax Remission Commission Direct federal or before the competent cantonal authority which forwards them to this committee with its proposal.

² The complaint procedure and the appeal procedure against decisions made before the entry into force of the amendment of 20 June 2014 of this Law shall be governed by the former right.

¹ For the first fiscal period following the entry into force of this Law, the tax on the net profit of legal persons shall be subject to provisional taxation according to the old and new rights. The tax calculated on the basis of the new fee is due if it is higher than the tax calculated under the old right; if that is not the case, it is the tax calculated from the old right that must be paid.

² The extraordinary profits earned in the fiscal years ended in calendar years n-2 and n-1 are subject to a special tax calculated in accordance with s. 68, provided that they are not used to cover losses for which the deduction is allowed.

³ Extraordinary profits include realized capital profits, accounting revaluations of wealth items, disclaimed provisions, and amortisation and allowances justified by commercial use that have been omitted.

⁴ If the business year extends to both calendar years n-1 and n, the tax corresponding to the year in n-1 shall be calculated on the basis of the old right and charged on the tax calculated under this Act, corresponding to the same period; Difference is not checked in.

¹ The capital income tax realized on the transfer of real property to the shareholder by a real estate company founded before the coming into force of this Act is reduced by 75 % if the corporation is dissolved.

² The amount of the excess wind-up tax obtained by the shareholder is reduced to the same extent.

³ The liquidation and cancellation of the real estate company must take place no later than 31 December 2003. ¹

⁴ Where the shareholder acquires from a real estate company, on a floor-by-floor basis and against the transfer of its interest, the share of the building for which the use is related to the transferred rights, the capital income tax Realized by the corporation is reduced by 75 % if the corporation was founded before 1 ^Er January 1995. In addition, the transfer of the complex to the shareholder must be recorded in the land registry by December 31, 2003. Under these conditions, the tax on the wind-up surplus obtained by the shareholder is reduced in the same proportion. ²

¹ Capital profits from investments as well as proceeds from the sale of the subscription rights are not included in the calculation of net return within the meaning of s. 70, para. 1, if the capital company or the cooperative corporation held the interests concerned before 1 ^Er January 1997 and realizes these profits before 1 ^Er January 2007.

² For interests held before 1 ^Er January 1997, the deeming values for income tax, at the beginning of the business year that is closed during the 1997 calendar year, are considered to be an investment cost (s. 62, para. 4, and 70, para. 4, let. (a).

³ If a capital corporation or a cooperative corporation transfers an interest that it held before 1 ^Er January 1997 to a company of the same group located outside Canada and that interest is equal to 20 % of the capital stock or share capital of another corporation, the difference between the determining value for income tax and the Venal value of this interest is added to taxable net income. In this case, the participating interests are considered to have been acquired before 1 ^Er January 1997. At the same time, the capital company or the cooperative corporation may be an untaxed reserve equal to that difference. This reserve will be dissolved and taxed if the interest is sold to a foreign third party to the group or if the corporation whose participation rights have been transferred alienates a significant portion of its assets and liabilities or if it is liquidated. The capital corporation or the cooperative corporation will attach to its tax return a list of interests that are subject to a non-imposed reserve within the meaning of this section. The non-imposed reserve is dissolved without tax implications on December 31, 2006.

⁴ If the business year ends after the effective date of the amendment of October 10, 1997, the tax on the profit is fixed for that business year under the new right.

¹ The cantonal surrender authority shall rule on applications for the remission of direct federal tax which, at the time of the entry into force of the amendment of this Law on 20 June 2014, are pending before the Federal Tax Remission Commission Direct federal or before the competent cantonal authority which forwards them to this committee with its proposal.

² The complaint procedure and the appeal procedure against decisions made before the entry into force of the amendment of 20 June 2014 of this Law shall be governed by the former right.