Lucius Cavelti
Kathrin Egli Arginelli
Robert Desax
Case law, practice and legislation 01/2025
In the first webinar of this series in 2025, we discuss the most important court decisions, latest trends and legal updates of recent months.
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Content
This webinar provides a concise overview of the development of tax law. Short, crisp and informative.
The following decisions of the Federal Supreme Court are discussed in detail:
BGE 149 II 354 et seq.
This decision is relevant in the following respects:
- Abuse of rights and revision
- Seat or actual administration?
- Tax evasion
- Duty to cooperate and provide information
BGer 9C_585/2024 (December 3, 2024)
This decision is relevant in the following respects:
- Domicile procedure and additional tax
- New facts in the proceedings
- Burden of proof and duty to cooperate
PE22.002105-//LGN, No. 408 (Cantonal Court VD)
This decision is relevant in the following respects:
- Criminal liability of the internal controller
and the external tax advisor - Tax evasion
- Monetary benefits / transfer pricing
- Negligence and intent
- Incitement
604 2023 115, 604 2023 116 (Cantonal Court FR, January 8, 2025)
This decision is relevant in the following respects:
- Criminal procedural guarantees (ECHR and BV)
- Open assessment procedure
- Tax evasion
- Duty to provide information in post-tax proceedings
BGer 9C_176/2024 ("Geneva Foundation Case", October 30, 2024)
This decision is relevant in the following respects:
- Capital distribution and income tax
- Definition of income
Current developments in tax law
Trump has 60 days to analyze foreign tax laws that contradict US tax treaties, are extraterritorial or disproportionately burden American companies.
The speakers will discuss what this means in the webinar.