Debt Push-Down: An Acquisition Structure leading to a Tax Effective Interest Deduction?
The typical structure of a Swiss target company acquired through an acquisition vehicle with subsequent merger and debt push-down is subject to income tax limitations set by the Swiss tax authorities. The authorities often take the view that interest expenses incurred after such merger cannot be deducted from taxable income. This newsletter outlines structuring options to minimize disadvantages resulting from the strict practice of the tax authorities.
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