Tax aspects of succession planning for operating companies owning real estate property
Entrepreneurs are often faced with the challenge that the takeover of their operating company by a successor is difficult to finance. This is particularly the case if the company holds considerable real estate property and has thus become very "heavy".
By splitting the operations and the real estate property into two companies, the operating company can be made “lighter”. This makes the financing of the acquisition more viable for a successor. However, such splits are usually not possible in a entirely tax-neutral manner and must therefore be carefully planned.
Especially in monistic cantons, i.e. in cantons where the increase in value on the real estate is subject to (cantonal or communal) real estate gains tax, a non-tax-neutral demerger can still be quite attractive and should therefore be considered.
In any case, careful tax planning is indispensable in succession planning.
