Hello my QC? I think I've made a little blooper...

👉 The taxpayers acquired 30% and then 70% from a company to a third party in two stages. Shortly after acquiring the first 30%, they contributed the shares to their holding company at market value. The tax authorities regarded this as a transfer.

The judgment is interesting in that it sets out everything that should not be done, including in terms of procedure. When everything goes wrong, everything goes wrong.

The ruling is in French. This is a Genevan case.

Federal Tribunal, judgment 9C_233/2025, of 1 October 2025