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.
Taxation of employees in the case of cross-border work in the home office
Sarah Bühler, René Matteotti and Peter Vogt address the taxation of international employees and their home office activities. They provide an overview of the existing regulations and pay particular attention to the cross-border commuter agreements with Switzerland's neighboring countries.
Implications of the home office for cross-border commuters between Switzerland and Germany
Working from home has become much more important due to the Corona pandemic. Many employers have found that working from home has proven successful and have introduced regulations that enable mobile working. This also affects cross-border commuters between Germany and Switzerland. A variety of tax regulations, especially in the DTA D-CH, as well as consequences under social security law must be taken into account.
In the future, the international automatic exchange of information will also include crypto assets
In a joint declaration, around 50 countries, including Switzerland, commit themselves to the expanded international automatic exchange of information in tax matters (AEOI). The extension affects crypto assets and is scheduled to apply from January 1, 2026. By the end of June 2024, the Federal Department of Finance (FDF) will prepare a consultation draft for the implementation of the expanded AEOI.
Switzerland and Italy agree on permanent tax rules for working from home
On 10 November 2023, Federal Councillor Karin Keller-Sutter and the Italian Minister of Finance and Economy signed a declaration that permanently regulates the issue of taxation of home office for cross-border commuters.
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 restructuring
Workshop on "Cross-border Restructuring" by Patrick Schmid and Thomas Hug on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 2023.
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.
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.
