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.
Federal Council adopts dispatch on amending the DTA with Germany
On June 14, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Germany.
Federal Council opens consultation on the new Federal Act on the International Automatic Exchange of Information on Salary Data
The Federal Council opened the consultation procedure at its meeting on June 7, 2024. It is proposing a new law that regulates the automatic exchange of information on salary data in tax matters between Switzerland and a partner state with which an international treaty exists.
Switzerland and Italy sign permanent tax rules for working from home
On June 6, 2024, Switzerland and Italy signed a protocol of amendment to the existing cross-border commuters agreement, which permanently regulates the issue of taxation of home offices. The protocol of amendment will enter into force as soon as the corresponding approval processes in both countries have been completed and will apply retroactively from January 1, 2024.
Publication of the report "Potential for the Swiss SME economy with a connection to the EU One-Stop-Shop for VAT settlement"
At its meeting on May 31, 2024, the Federal Council adopted the report in fulfillment of postulate 22.3384 of the WAK-N of April 11, 2024.
Federal Council opens consultation on extending the international automatic exchange of information in tax matters to crypto assets
The extension concerns the new AEOI on crypto assets and the amendment to the standard for AEOI on financial accounts and is to apply from January 1, 2026.
Federal Council adopts dispatch on the amendment of the DTA with Serbia
On May 1, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Serbia.
OECD clarifies the commentary on Article 26 (exchange of information)
On February 19, 2024, the OECD Council updated the commentary on Article 26 of the OECD Model Tax Convention. It was clarified that information received in the context of administrative tax assistance can also be used in relation to unnamed persons.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Current cases on intercantonal and international corporate tax law (2024)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current cases on intercantonal and international corporate tax law"
Special issues in trust and foundation structures
Workshop on "Special Issues in Trust and Foundation Structures" by Andrea Opel and Stefan Oesterhelt on the occasion of the ISIS seminar "Structuring Private Assets by Means of Trusts or Foundations" on October 31, 2023.
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.
