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.
The new double taxation agreement between Italy and Liechtenstein - advantages and specific cases of application
On July 12, 2023, Liechtenstein and Italy signed a double taxation agreement (DTA). The agreement is based on the international standard of the OECD Model Tax Convention 2017, takes into account the results of the BEPS project and follows the agreement on the exchange of information (TIEA) that was concluded with Italy in 2015. The DTA increases legal certainty, leads to significant withholding tax reductions, reduces existing barriers to investment and financing and will make a decisive contribution to further strengthening cooperation between the two countries.
The definition of turnover according to the Minimum Tax Ordinance
According to the Minimum Tax Ordinance (MindStV), business units belonging to Switzerland are subject to Swiss supplementary tax if they belong to a group of companies with a turnover of at least EUR 750 million. The concept of turnover as a central prerequisite for subjective tax liability is only rudimentarily regulated in the ordinance. This article examines this concept from different perspectives with reference to various OECD/G20 documents and identifies open questions.
Taxation of spouses in international relations - tax segregation issues
In the zsis) issue of November 2019, the authors dealt with tax law stumbling blocks in the taxation of spouses in international relationships. In this article, they have focused on the tax segregation of international spouses. On the basis of a test scheme with three questions, they show that a systematic procedure is essential for correct tax segregation and that there is still a need for action here on the part of the assessment authority and the courts.
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OECD/G20 Inclusive Framework publishes new multilateral agreement to address the tax challenges of globalisation and digitalisation
On 11 October 2023, the OECD/G20 Inclusive Framework published a new multilateral agreement to address the tax challenges of globalisation and digitalisation.
Entry into force of the DTA between Switzerland and Ethiopia
On September 21, 2023, SIF announced that the DTA Switzerland - Ethiopia entered into force on August 10, 2023. The provisions are applicable for Switzerland as of January 1, 2024 and in Ethiopia as of July 8, 2024.
Switzerland and Serbia sign Protocol of Amendment to Double Taxation Agreement
On September 19, 2023, Switzerland and Serbia signed a Protocol of Amendment to the DTA, which implements the minimum standards in double taxation treaty matters.
Switzerland and Germany sign protocol of amendment to DTA
Switzerland and Germany signed the revision protocol amending the DTA of 11 August 1971 on 21 August 2023 on the fringes of the meeting of German-speaking finance ministers in Aschau im Chiemgau.
FDF publishes first report on cantonal measures in connection with the implementation of the OECD minimum tax
On August 8, 2023, the FDF published the first report on the expected impact of the implementation of the OECD minimum tax on the individual cantons as well as the planned measures of the individual cantons as of May 31, 2023.
Cross-border commuter agreement with Italy has entered into force
On July 19, 2023, SIF announced that the new cross-border commuter agreement with Italy and an amending protocol to the DTA entered into force on July 17, 2023. The provisions are applicable as of January 1, 2024.
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