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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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 Ireland sign Protocol of Amendment to the DTA
Switzerland and Ireland signed a Protocol of Amendment to the Convention on the Avoidance of Double Taxation in the Field of Taxes on Income and Capital (DTA) on 13 June 2019.
Switzerland and the Netherlands sign Protocol of Amendment to the DTA
On 12 June 2019, Switzerland and the Netherlands signed a Protocol of Amendment to the Convention on the avoidance of double taxation in the area of taxes on income (DTA).
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.
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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.
