One Uber as a digital business location?
Based on the concrete example of Uber , the aim of this paper is to find answers to the following questions: Can users play a decisive role in the value creation of a company in the digital economy? And if so, how can they be used to address the challenges of taxation in the digital economy?
The Liechtenstein "Blockchain Law" (TVTG) from the perspective of tax consulting
The article shows that although there is now a legal basis for the token economy in Liechtenstein, no adjustments to the tax law are necessary. This is because the economic approach to tax law means that a situation can be subsumed and assessed from a tax perspective regardless of the technology used.
The Liechtenstein private law establishment with divided or undivided capital
The Liechtenstein private law establishment is a very versatile and flexible legal form which is unknown under Swiss company law and cannot generally be assigned to corporations or foundations. The article deals with the "establishment" as a special feature of Liechtenstein company law.
Taxation of spouses in international relations
An "international" spouse relationship from a tax law perspective exists if only one spouse is subject to unlimited tax liability in Switzerland, while the other spouse has no or only limited tax liability in Switzerland. It must also be a legally and factually unseparated marriage. The taxation of such "international" spousal relationships is opposed by the addition of factors as prescribed by law. However, according to the established case law of the Federal Supreme Court, the latter - unlike in intercantonal relations - cannot create any tax liability in Switzerland.
ESTV - Agreement on mutual understanding between Switzerland and Austria
The State Secretariat for International Financial Matters SIF reported on 12 November 2020 the conclusion of a new Memorandum of Understanding between Switzerland and Austria on the implementation of Article 25 paragraph 5 (arbitration).
Federal Council adopts dispatches on the amendments to the DTAs with Liechtenstein, Malta and Cyprus
On 11 November 2020 the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Liechtenstein, Malta and Cyprus. The protocols implement the DTA minimum standards.
Federal Council puts revised law and ordinance on AIA into force
In the course of an examination of the Global Forum's audit of Switzerland, recommendations were made. The amendments take these into account and include in particular the abolition of the exemption for condominiums communities and an adjustment of the applicable due diligence obligations.
Federal Council adopts dispatch on the Federal Act on the Implementation of International Agreements in the Tax Field
On 4 November 2020, the Federal Council adopted the dispatch on the totally revised Federal Act of 1951 on the Implementation of Interstate Agreements of the Confederation for the Avoidance of Double Taxation (new: StADG).
FTA - Memorandum of Understanding between Switzerland and Liechtenstein
On 27 October 2020, the State Secretariat for International Financial Matters SIF reported the conclusion of a new memorandum of understanding between Switzerland and Liechtenstein on the effects of measures to combat COVID-19 on the treatment of cross-border commuters under the DTA.
Federal Councillor Ueli Maurer meets with Ticino government on the agreement with Italy on cross-border commuters
On 16 October 2020, Federal Councillor Ueli Maurer met with the Cantonal Government of Ticino and informed about the latest exchange with the Italian Ministry of Finance on the agreement with Italy on the taxation of cross-border commuters.
OECD public consultation on Pillar One and Pillar Two in the taxation of digital business models
On 12th October the OECD published the blueprints for Pillar One and Pillar Two and launched a public consultation until 14th December 2020. The aim is to reach an agreement between the states on the open points by mid 2021.
FTA publishes understanding agreement on the DTA with Liechtenstein
On 12 October 2020, the State Secretariat for International Financial Matters (SIF) published a memorandum of understanding on the DTA with Liechtenstein concerning the treatment of income of FC Vaduz players resident in Switzerland under the DTA between Switzerland and Liechtenstein.
Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
Current cases on intercantonal and international corporate tax law
Workshop from the ISIS) seminar on 2/3 March 2020 entitled "Corporate Tax Law 2020
Structuring of real estate assets with a view to estate planning
Workshop on the occasion of the ISIS) seminar of 28 November 2019 entitled "Tax Aspects of Estate Planning for Real Estate".
Possibilities and limits of tax planning for investments of natural persons - national and international
Workshop on the occasion of the ISIS seminar on 9/10 September 2019 entitled "Tax planning in the area of conflict between cost optimisation, tax compliance and Good citizenship - opportunities and risks".