The articles of the zsis) - Center for Swiss and International Tax Law are summarized in quarterly issues at the end of each quarter. Register for free and read the current quarterly issue.
The articles of the zsis) - Center for Swiss and International Tax Law are summarized in quarterly issues at the end of each quarter. Register free of charge and read the current quarterly issue including the main topics.
You can find all quarterly issues from 2019 onwards in our archive.
The zsis - Center for Swiss and International Tax Law is a digital information and research platform for practitioners. Our articles are divided into nine tax law topics and are marked with the corresponding colours. These articles appear in the following formats: articles, Tax Snacksnews, papers and documents.
In the following you will find a selection of the latest articles...
Since the concept of the place of actual administration was incorporated into the law in 1951, digitisation has progressed in great strides. The author explores the question of the extent to which, in the age of home offices and video conferencing via the internet, criteria such as office space, lack of staff, lack of telephone accessibility and address redirection are still contemporary and whether the place of actual administration can still be determined geographically at all in the face of increasing mobility.
René Matteotti, Peter Vogt and Natalja Ezzaini examine how the Swiss authorities dealt with the tax issues that arose as a result of the Covid 19 pandemic, which involved international employees and their work in home offices.
Employees are more mobile than ever. As a result, they often have occupational and private pension assets in several countries. The tax situation becomes confusing at the latest when a cross-border transfer or payment of these pension assets to the beneficiaries is to take place. This article first introduces the basics and presents the respective tax consequences in Switzerland with regard to the payout from the foreign pension forms on the basis of two cross-border practical examples.
The Protocol of Amendment to the Double Taxation Treaty between Switzerland and the USA, which was approved on 17 July 2019, provides that dividends paid to tied pension institutions (e.g. pillar 3a) will be exempt from withholding tax from 1 January 2020, provided that they do not control the US company paying the dividends.
On 19 May 2021, a Protocol of Amendment to the DTA Switzerland - Northern Macedonia was signed, which implements the minimum standards in DTA matters.
The Federal Tax Administration (FTA) has updated the list of amendments to laws and ordinances with entry into force in the years 2021-2024.
Since the 2020 tax period, there is the new deductibility of deconstruction costs with regard to a replacement new building (section 30 para. 2 StG) and the transferability of expenses for investments that serve to save energy and protect the environment, as well as deconstruction costs with regard to a replacement new building (section 30 para. 2bis StG). These costs are deductible in the two subsequent tax periods insofar as they could not be fully taken into account for tax purposes in the current tax period. The two information sheets were adapted for this purpose:
On 7 May 2021, the Federal Tax Administration (FTA) posted material adjustments re: Covid 19 contributions to the Value Added Tax Act (VAT Act).
On 27 April 2021, the FTA posted the first drafts of the VAT practice on its website, which concern the following topics:
Germany and Switzerland have amended the consultation agreement again with the date 27 April 2021.
On 30 April 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
The Federal Council wants to strengthen Switzerland as a location for the debt capital market and for group financing activities in all sectors.
The double taxation agreement (DTA) in the area of taxes on income between Switzerland and Brazil entered into force on 16 March 2021 and the DTA with Saudi Arabia in the area of taxes on income and assets entered into force on 1 April 2021. Both DTAs are effective from 1 January 2022.
The Federal Tax Administration updated the selected parliamentary business in the tax area at federal level on 7 April 2021.
On 26.03.2021, the Cantonal Tax Office of Zurich published a notice according to which dependent employees can claim their professional expenses for the year 2021, as they did for the year 2020, as if there had been no measures to combat the Corona pandemic.
The Federal Tax Administration (FTA) published material amendments to the Value Added Tax Act (VAT Act) on 22 March 2021.
In a letter dated 5 February 2021, the IRS requests administrative assistance based on the FATCA agreement and the DTA CH-USA. Information is requested on accounts that were identified as US accounts or as accounts of non-participating financial institutions to which foreign reportable amounts were paid and which the respective financial institution had reported in aggregated form - in the absence of consent to report the account data. The following financial institutions and years are affected:
