STAF transitional rules from an international perspective
Developments in international tax law have increased rapidly in recent years. The BEPS project to combat base erosion and profit shifting (BEPS), initiated by the OECD and the G20 countries, was the main trigger for this unprecedented dynamic. With a comprehensive package of measures consisting of 15 action points, the aim is to take international action against harmful tax competition and aggressive tax structuring and thus prevent undesirable profit reduction and profit shifting.
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.
Technical information "Withholding tax according to DTA" has been updated
The following documents have been updated:
FTA updates the publication "Tax burden in international comparison
The publication summarises the tax rates and tax ratios in various OECD countries. Among other things, it compares corporate tax rates, capital tax rates for companies, withholding tax rates, emissions and turnover taxes, VAT rates and the treatment of losses in 2020. In particular, the publication also contains various statements on the ratio of direct to indirect taxes.
FTA updates guidance on the standard for AEOI in tax matters
The FTA has updated the guidance on the standard for the automatic exchange of information (AEOI) in tax matters.
New cross-border commuter agreement between Switzerland and Italy of 23 December 2020
On 23 December 2020, Switzerland and Italy signed a new agreement on cross-border commuters, which replaces the current agreement of 1974 and now applies reciprocally.
Canton of Zurich: Tax segregation of companies with foreign permanent establishments
Section 57 para. 3 StG ZH was adapted to the corresponding provision in the law on direct federal tax with effect from 01 January 2021.
Memorandum of Understanding with the Philippines
The State Secretariat for International Financial Matters SIF has concluded a mutual agreement with the Philippines on the recognition and provision of Philippine tax residency certificates. This agreement will enter into force on 10 December 2020.
FTA publishes notices on FATCA group requests
On 1 December 2020, the Federal Tax Administration (FTA) published FATCA group requests pursuant to Article 12(1) of the FATCA Law.
Consultation agreement with Germany on cross-border workers and state benefits extended
The State Secretariat for International Financial Matters (SIF) reported on 3 December 2020 that the consultation agreement between Switzerland and Germany on the taxation of cross-border commuters and treatment of state support benefits will remain in force until 31 March 2021 (see our article of 13 June 2020).
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".