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.
Federal Council adopts dispatch on amending the DTA with Germany
On June 14, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Germany.
Federal Council opens consultation on the new Federal Act on the International Automatic Exchange of Information on Salary Data
The Federal Council opened the consultation procedure at its meeting on June 7, 2024. It is proposing a new law that regulates the automatic exchange of information on salary data in tax matters between Switzerland and a partner state with which an international treaty exists.
Switzerland and Italy sign permanent tax rules for working from home
On June 6, 2024, Switzerland and Italy signed a protocol of amendment to the existing cross-border commuters agreement, which permanently regulates the issue of taxation of home offices. The protocol of amendment will enter into force as soon as the corresponding approval processes in both countries have been completed and will apply retroactively from January 1, 2024.
Publication of the report "Potential for the Swiss SME economy with a connection to the EU One-Stop-Shop for VAT settlement"
At its meeting on May 31, 2024, the Federal Council adopted the report in fulfillment of postulate 22.3384 of the WAK-N of April 11, 2024.
Federal Council opens consultation on extending the international automatic exchange of information in tax matters to crypto assets
The extension concerns the new AEOI on crypto assets and the amendment to the standard for AEOI on financial accounts and is to apply from January 1, 2026.
Federal Council adopts dispatch on the amendment of the DTA with Serbia
On May 1, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Serbia.
OECD clarifies the commentary on Article 26 (exchange of information)
On February 19, 2024, the OECD Council updated the commentary on Article 26 of the OECD Model Tax Convention. It was clarified that information received in the context of administrative tax assistance can also be used in relation to unnamed persons.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Current cases on intercantonal and international corporate tax law (2024)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current cases on intercantonal and international corporate tax law"
Special issues in trust and foundation structures
Workshop on "Special Issues in Trust and Foundation Structures" by Andrea Opel and Stefan Oesterhelt on the occasion of the ISIS seminar "Structuring Private Assets by Means of Trusts or Foundations" on October 31, 2023.
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.
