The Federal Supreme Court recently issued its first ruling on the method by which trust assets are to be attributed to the beneficiary of an irrevocable fixed interest trust. This has clarified an important issue for beneficiaries of irrevocable fixed-interest trusts residing in Switzerland regarding both the correct declaration of trust interests and prior ruling requests to the tax authorities, even though certain points remain open, namely which capitalization rate applies and whether a pro-rata attribution remains possible.

Gilles Haudenschild and Michael Fischer commented on the landmark decision on iusnet Erbrecht: Link to the article.