"Mother-daughter" arrangement between Italy and Switzerland
Opinion No. 537 of 6 August 2021 of the Italian tax authorities, described in this article, is a further sign of the "normalisation" of income tax relations between Italy and Switzerland.
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.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Federal Council adopts dispatch on the new Federal Act on the International Automatic Exchange of Information on Salary Data
At its meeting on May 14, 2025, the Federal Council adopted the dispatch on the international automatic exchange of information on salary data.
Federal Council wants to amend the minimum taxation ordinance
At its meeting on April 30, 2025, the Federal Council opened the consultation on an amendment to the Minimum Tax Ordinance (MindStV). The Minimum Tax Ordinance is to be supplemented by the rules on the international reporting obligation (GloBE Information Return, GIR).
Tax relief for Norway
On April 24, 2025, the SIF published an overview of the effects of the agreement on tax relief for Norway.
Tax relief for various countries
On April 7, 2025, the SIF updated the overview of the effects of the agreement (extent of relief) for various countries.
Switzerland and Zimbabwe sign a double taxation agreement
On March 19, 2025, Switzerland and Zimbabwe signed an agreement on the avoidance of double taxation (DTA) in the area of income taxes in Harare.
Memorandum of Understanding between Switzerland and Italy - Administrative cooperation
On March 19, 2025, the SIF reported that the competent authorities of Switzerland and Italy, in accordance with Art. 7 para. 1 of the Agreement of December 23, 2020 between Switzerland and Italy on the taxation of cross-border commuters, have defined the details of the application of administrative cooperation by mutual agreement.
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".
