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 the dispatch on the amendment of the AIA Act
At its meeting on 20 November 2019, the Federal Council adopted the dispatch on the amendment of the Federal Act on the International Automatic Exchange of Information in Tax Matters (AIAG).
OECD publishes consultation document on the introduction of a global minimum tax on profits
As part of its project on taxation of the digital economy, the Organisation for Economic Cooperation and Development (OECD) published the consultation document on the introduction of a global minimum tax on profits (so-called "Global anti-Base Erosion" or "GloBE") on 8 November 2019.
Federal Council adopts dispatches on the amendments to the DTAs with New Zealand, the Netherlands, Norway and Sweden
At its meeting on 6 November 2019, the Federal Council adopted the dispatches concerning the amendment protocols to the double taxation agreements (DTAs) with New Zealand, the Netherlands, Norway and Sweden.
Federal Council adopts dispatch on the amendments to the DTA with Iran
At its meeting on 23 October 2019, the Federal Council adopted the dispatch on the Protocol of Amendment to the Agreement on the avoidance of double taxation in the area of taxes on income and wealth (DTA) with Iran.
OECD publishes proposal on taxation of multinational companies
On 9 October 2019, the Organisation for Economic Cooperation and Development (OECD) published a proposal to ensure that large and highly profitable multinational companies, especially IT companies, pay taxes.
EU removes Switzerland from its watch list
Switzerland meets international tax standards and implements them. The European Union is now acknowledging this and removing Switzerland from its watch list. The amendment shall enter into force upon publication of the revised Annexes in the Official Journal of the EU.
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).
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Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Remboursement de l'impôt anticipé: pratique des anciennes réserves, liquidation remplaçante et transposition internationale étendue
Cas pratiques présentés par Stefan Oesterhelt et Raphaël Fellay lors du séminaire ISIS) du 03 novembre 2021, intitulé "Restructurations / Fusions / Acquisitions".
