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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Consultation agreement with Germany on the taxation of railway staff
On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
SIF publishes peer review report of the Global Forum
On 6 April 2020, the State Secretariat for International Financial Matters (SIF) published the peer review report on the exchange of information upon request for tax purposes.
FTA - Key figures on international administrative assistance
On 27 February 2020, the Federal Tax Administration updated the key figures on international administrative assistance in 2019.
OECD publishes report on transfer prices in financial transactions
On 11 February 2020, the Organisation for Economic Cooperation and Development (OECD) published a report containing guidelines on the transfer pricing aspects of financial transactions.
OECD publishes statement on taxation of multinational companies
On 31 January 2020, the Organisation for Economic Cooperation and Development (OECD) published a statement on taxation of multinational (digital) companies, according to which an agreement should be in place by the end of 2020 (see also taxlawblog contributions of 12 October 2019 and 9 November 2019).
SIF updates list of DTAs with abuse provisions
On 17 January 2020, the Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) updated the list of agreements with abuse provisions.
Federal Council opens consultation on the Federal Act on the Implementation of International Tax Treaties
At its meeting on 13 December 2019, the Federal Council opened the consultation process on the Federal Act on the Implementation of International Agreements in the Tax Field (new StADG). The consultation period will last until 27 March 2020.
BEPS Convention entered into force on 1 December 2019
The Multilateral Agreement on the Implementation of Agreement-Based Measures to Prevent the Reduction and Transfer of Profits ("BEPS Agreement") has been in force since 1 December 2019. With the help of the Convention, existing double taxation agreements can be adapted to the recommendations from the BEPS project.
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Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
Current cases on intercantonal and international corporate tax law
Workshop from the ISIS) seminar on 2/3 March 2020 entitled "Corporate Tax Law 2020
Structuring of real estate assets with a view to estate planning
Workshop on the occasion of the ISIS) seminar of 28 November 2019 entitled "Tax Aspects of Estate Planning for Real Estate".
Possibilities and limits of securing tax planning (rulings, notifications, assurances, preliminary notices and the like), exchange of information, administrative and legal assistance
Workshop on the occasion of the ISIS seminar on 9/10 September 2019 entitled "Tax planning in the area of conflict between cost optimisation, tax compliance and Good citizenship - opportunities and risks".
