Refund of withholding tax in international relations
The refund of withholding tax on dividends from Swiss companies by foreign shareholders can only be made on the basis of a double taxation agreement between Switzerland and the country of residence of the claimant. In order to claim relief from withholding tax under the applicable double taxation treaty, the residence of the claimant must be confirmed by the foreign tax authorities.
Transfer of the registered office to Switzerland - A case for the old reserve practice?
The problem of old reserves has become an integral part of daily tax consulting practice in Switzerland. The corresponding problem will be examined in this article on the basis of a transfer of the registered office of a foreign company to Switzerland. Here, too, the Federal Tax Administration (FTA) initially assumed that the "old reserves" brought into Switzerland were subject to Swiss abuse practice without restriction.
Place of actual administration in the age of digitalisation & home office
Since the concept of the place of actual administration was incorporated into the law in 1951, digitisation has progressed in great strides. The author explores the question of the extent to which, in the age of home offices and video conferencing via the internet, criteria such as office space, lack of staff, lack of telephone accessibility and address redirection are still contemporary and whether the place of actual administration can still be determined geographically at all in the face of increasing mobility.
Federal Council adopts dispatch on the Protocol of Amendment to the DTA with Ukraine
At its meeting on 9 October 2019, the Federal Council approved the dispatch on the approval of a Protocol of Amendment to the Agreement to Avoid Double Taxation in the Area of Taxes on Income and Capital (DTA) between Switzerland and Ukraine. The protocol implements the minimum standards in double taxation agreements and also adapts the DTA to the current treaty policy of the two states.
Exchange of information with 75 countries on around 3.1 million financial accounts
According to the media release of the Federal Tax Administration (FTA) of 7 October 2019, the FTA has exchanged information on financial accounts with 75 countries. The exchange takes place within the framework of the global standard for automatic information exchange (AIA).
Protocol of Amendment to the DTA between Switzerland and the United States of America comes into force
Switzerland and the United States of America exchanged the instruments of ratification of the Protocol of Amendment to their Double Taxation Convention in the area of taxes on income (DTA) in Bern on 20 September 2019. The Protocol, which came into force on the same day, represents a milestone in tax relations between Switzerland and the USA.
Federal Council adopts dispatches on the amendments to the DTAs with Ireland and Korea
At its meeting on 20 September 2019, the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Ireland and Korea. The protocols implement the minimum standards in the area of DTAs. In addition, an arbitration clause is included in the DTA with Ireland. Both messages were referred to the Federal Assembly.
Federal Supreme Court ruling of 26 July 2019 (2C_653/2018): Administrative assistance to France regarding the identity of UBS clients
The Swiss Federal Tax Administration (FTA) may provide France with information regarding the identity of UBS clients presumed to be taxable in France.
Switzerland and Iran sign Protocol of Amendment to the DTA
On 3 June 2019, Switzerland and Iran signed an amendment protocol to the double taxation agreement (DTA) in the area of taxes on income and assets.
Implement the recommendations of the Global Forum on transparency and exchange of information for tax purposes
The Council of States and the National Council have adopted the federal law implementing recommendations of the Global Forum on transparency and exchange of information for tax purposes.
Federal Council adopts dispatch on the introduction of AIA with 19 other countries and approves audit report
At its meeting on 29 May 2019, the Federal Council opened the Dispatch on the introduction of the automatic exchange of information on financial accounts (AIA) with 19 other states and territories.
Appeal proceedings taking into account intercantonal and international aspects (2 parts)
Workshop by Ruth Bloch-Riemer and Toni Hess on the occasion of the ISIS) seminar on May 5, 2025 entitled "Appeal procedures taking into account intercantonal and international aspects (2 parts)"
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"
