Cross-border commuter regulation Switzerland-France
The home office has fundamentally changed cross-border taxation - also in the relationship between Switzerland and France. New rules have applied to French cross-border commuters since 2023, which allow more flexibility but also place greater demands on employers and employees. This article provides a concise overview of the current tax framework and shows what should be paid particular attention to.
Tax-exempt legal entities for profit and supplementary taxes in Switzerland - A legal comparison
Not only the federal, cantonal and communal taxes on profits (DBG, StHG), but also the supplementary taxes (GloBE model regulations, MindStV) recognize the concept of subjective tax exemption for legal entities. The regulations are basically congruent, but there are several case constellations of practical relevance in which the supplementary taxes override the profit tax exemption (e.g. cantonal banks, health insurance companies, newly established companies). The author therefore sees a need for action on the part of legislators and tax authorities.
Taxation of spouses in international relationships - Federal Supreme Court ruling of September 23, 2024 Prejudice on tax separation issues
In its ruling of September 23, 2024, the Federal Supreme Court issued a long-awaited precedent on the issue of international tax differentiation of debts and debt interest in the case of international spouses and revised its ruling of March 2023 on the international transfer of maintenance payments to the divorced spouse. What does this precedent mean for practice and how should other exciting practical cases be handled?
Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Federal Council adopts dispatch on the new Federal Act on the International Automatic Exchange of Information on Salary Data
At its meeting on May 14, 2025, the Federal Council adopted the dispatch on the international automatic exchange of information on salary data.
Federal Council wants to amend the minimum taxation ordinance
At its meeting on April 30, 2025, the Federal Council opened the consultation on an amendment to the Minimum Tax Ordinance (MindStV). The Minimum Tax Ordinance is to be supplemented by the rules on the international reporting obligation (GloBE Information Return, GIR).
Tax relief for Norway
On April 24, 2025, the SIF published an overview of the effects of the agreement on tax relief for Norway.
Tax relief for various countries
On April 7, 2025, the SIF updated the overview of the effects of the agreement (extent of relief) for various countries.
Switzerland and Zimbabwe sign a double taxation agreement
On March 19, 2025, Switzerland and Zimbabwe signed an agreement on the avoidance of double taxation (DTA) in the area of income taxes in Harare.
Memorandum of Understanding between Switzerland and Italy - Administrative cooperation
On March 19, 2025, the SIF reported that the competent authorities of Switzerland and Italy, in accordance with Art. 7 para. 1 of the Agreement of December 23, 2020 between Switzerland and Italy on the taxation of cross-border commuters, have defined the details of the application of administrative cooperation by mutual agreement.
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
Social security law
Workshop by Franziska Stadtherr and Andreas Schiek on the occasion of the ISIS) seminar on May 22, 2025 entitled "Social Security Law"
