Facts
On 16 July 2008, [X. AG] , headquartered in [A.] /SZ, acquired a 100% stake in [Y. AG] , headquartered in [C.] /TG. The purchase price was CHF 4'400'000.--. In the 2009 financial year, [X. AG] wrote down the "Goodwill" of the investment by CHF 1'341'594.49 (around 36 percent). The tax authorities declared this write-down as not commercially justified and added the amount to the taxable profit.Considerations
The Federal Court held that the valuation method applied by the lower instance, which is primarily based on the audited financial statements for 2008 and 2009, is in compliance with federal law. Given the short holding period of the investment and the lack of empirical data on the actual business operations in the present legal form and under the current shareholder structure, this method is reasonable. The Federal Court intervenes only with restraint if the lower instance has chosen a comprehensible, plausible and recognized valuation method.
Furthermore, the Federal Court found that the…