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.
Taxation of international workers during the Covid 19 pandemic
René Matteotti, Peter Vogt and Natalja Ezzaini examine how the Swiss authorities dealt with the tax issues that arose as a result of the Covid 19 pandemic, which involved international employees and their work in home offices.
Tax aspects of pension assets of internationally mobile employees
Employees are more mobile than ever. As a result, they often have occupational and private pension assets in several countries. The tax situation becomes confusing at the latest when a cross-border transfer or payment of these pension assets to the beneficiaries is to take place. This article first introduces the basics and presents the respective tax consequences in Switzerland with regard to the payout from the foreign pension forms on the basis of two cross-border practical examples.
STAF transitional rules from an international perspective
Developments in international tax law have increased rapidly in recent years. The BEPS project to combat base erosion and profit shifting (BEPS), initiated by the OECD and the G20 countries, was the main trigger for this unprecedented dynamic. With a comprehensive package of measures consisting of 15 action points, the aim is to take international action against harmful tax competition and aggressive tax structuring and thus prevent undesirable profit reduction and profit shifting.
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Federal Council adopts dispatches on the amendments to the DTAs with Liechtenstein, Malta and Cyprus
On 11 November 2020 the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Liechtenstein, Malta and Cyprus. The protocols implement the DTA minimum standards.
Federal Council puts revised law and ordinance on AIA into force
In the course of an examination of the Global Forum's audit of Switzerland, recommendations were made. The amendments take these into account and include in particular the abolition of the exemption for condominiums communities and an adjustment of the applicable due diligence obligations.
Federal Council adopts dispatch on the Federal Act on the Implementation of International Agreements in the Tax Field
On 4 November 2020, the Federal Council adopted the dispatch on the totally revised Federal Act of 1951 on the Implementation of Interstate Agreements of the Confederation for the Avoidance of Double Taxation (new: StADG).
FTA - Memorandum of Understanding between Switzerland and Liechtenstein
On 27 October 2020, the State Secretariat for International Financial Matters SIF reported the conclusion of a new memorandum of understanding between Switzerland and Liechtenstein on the effects of measures to combat COVID-19 on the treatment of cross-border commuters under the DTA.
Federal Councillor Ueli Maurer meets with Ticino government on the agreement with Italy on cross-border commuters
On 16 October 2020, Federal Councillor Ueli Maurer met with the Cantonal Government of Ticino and informed about the latest exchange with the Italian Ministry of Finance on the agreement with Italy on the taxation of cross-border commuters.
OECD public consultation on Pillar One and Pillar Two in the taxation of digital business models
On 12th October the OECD published the blueprints for Pillar One and Pillar Two and launched a public consultation until 14th December 2020. The aim is to reach an agreement between the states on the open points by mid 2021.
FTA publishes understanding agreement on the DTA with Liechtenstein
On 12 October 2020, the State Secretariat for International Financial Matters (SIF) published a memorandum of understanding on the DTA with Liechtenstein concerning the treatment of income of FC Vaduz players resident in Switzerland under the DTA between Switzerland and Liechtenstein.
FTA - Memorandum of Understanding between Switzerland and Australia
On 15 September 2020 the Memorandum of Understanding on the procedural rules of the arbitration procedure provided for in Article 24 (Mutual agreement procedure) paragraph 5 of the Double Taxation Convention Switzerland - Australia was signed.
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