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.
The Confederation regulates the implementation of the OECD minimum tax in Switzerland
In order to implement the OECD/G20 project on the taxation of the digital economy, the Federal Council proposes a supplementary tax, with 25% of the revenue going to the Confederation and 75% to the cantons and municipalities.
VAT refund to foreign companies
The Federal Administrative Court has confirmed the practice of the FTA regarding the content of the entrepreneur's certificate: This must be valid for the remuneration period (calendar year).
Federal Council adopts dispatch on AEOI with 12 other partner states
At its meeting on 18 May 2022, the Federal Council adopted the dispatch on the introduction of AEOI with 12 other partner states.
Federal Council adopts dispatch on the amendment of the double taxation agreement with Armenia
The Federal Council adopted the dispatch on the Protocol of Amendment to the DTA on 4 May 2022.
Memorandum of Understanding between Switzerland and France
On 12 April 2022, SIF notified the conclusion of a mutual agreement dated 11 April 2022 to repeal the mutual agreement on the effects of measures to combat Covid-19 under the Switzerland-Germany DTA.
Working visit by Federal Councillor Ueli Maurer to his German counterpart
Federal Councillor Ueli Maurer met the German Finance Minister Christian Lindner for a working visit on 28 March 2022. The exchange concerned, among other things, the OECD/G20 project on taxing the digital economy.
Federal Council adopts dispatch on DTA with Ethiopia
On 18 March 2022, the Federal Council adopted the dispatch on the DTA with Ethiopia. With this DTA, Switzerland is extending its network of agreements to East Africa for the first time.
Federal Council opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
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 tax planning for inheritances and gifts - national and international
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".
