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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Switzerland and South Korea sign Protocol of Amendment to the DTA
On 17 May 2019, Switzerland and South Korea signed a Protocol of Amendment to the Double Taxation Convention (DTA) in the area of taxes on income.
Protocol of Amendment to the DTA with Ecuador enters into force
The Protocol amending the Double Taxation Convention (DTA) between Switzerland and Ecuador in the area of taxes on income and wealth entered into force on 17 April 2019.
SIF publishes agreement on DTA between Switzerland and Colombia
On 5 March 2019, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MoU) on the Agreement between the Swiss Confederation and the Republic of Colombia on the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 26 October 2007 (DTA Switzerland-Colombia).
National Council against report on tax evasion
The National Council does not want to know the extent to which taxes are evaded in Switzerland. On Wednesday he refused to demand a report from the Federal Council.
National Council does not want a code of interpretation on tax self-reports
The National Council does not consider it necessary to know how the number of voluntary reports of tax evaders with impunity has developed since 2010. It narrowly refused by 98 votes to 93 to commission the Federal Council with a report on the matter. Even the latter would have considered it useful.
National Council approves agreement against tax avoidance
Parliament supports the implementation of international standards against corporate tax avoidance. Following the Council of States, the National Council has also come out in favour of an agreement.
Double Taxation Convention
The Commission also follows the decision of the National Council from the last winter session and requests approval of the double taxation agreement with Brazil (18,064; 10 votes to 1 with 1 abstention) and the United Kingdom (18,062; unanimously).
Withholding tax according to DBA
The Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) has updated the overviews of the contractual limits on foreign taxes, the tax relief for Swiss dividends and interest, and the countries whose agreements contain abuse provisions.
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ISIS) seminar folder "Corporate Restructuring" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Corporate Restructuring" of August 29, 2023 under the direction of René Schreiber.
Current cases on intercantonal and international corporate tax law (2023)
Workshop on intercantonal and international corporate tax law by René Matteotti and Philipp Betschart on the occasion of the ISIS seminar "Corporate Tax Law 2023" on June 19/20, 2023.
Intercantonal and cross-border real estate transactions
Workshop by Laetitia Fracheboud and Olivier Margraf on the occasion of the ISIS) seminar of 12/13 September 2022 entitled "Intercantonal and cross-border land transactions".
Seminar folder ISIS)-Seminar "Real Estate Transactions - Tax Consequences National and Cross-Border
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Real Estate Transactions - Tax Consequences National and Cross-Border" from September 12 and 13, 2022 under the direction of Julia von Ah.
