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.
One Uber as a digital business location?
Based on the concrete example of Uber , the aim of this paper is to find answers to the following questions: Can users play a decisive role in the value creation of a company in the digital economy? And if so, how can they be used to address the challenges of taxation in the digital economy?
The Liechtenstein "Blockchain Law" (TVTG) from the perspective of tax consulting
The article shows that although there is now a legal basis for the token economy in Liechtenstein, no adjustments to the tax law are necessary. This is because the economic approach to tax law means that a situation can be subsumed and assessed from a tax perspective regardless of the technology used.
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.
Supplementary tax: Tax treatment of business units that qualify as permanent establishments
On March 18, 2025, the FTA explained the treatment of business units that are considered permanent establishments in a communication on the minimum taxation of multinational enterprise groups.
Federal Council opens consultation on change to FATCA model
At its meeting on March 7, 2025, the Federal Council opened the consultation process for a new FATCA agreement.
Federal Council opens consultation on the exchange of information on OECD minimum taxation
On January 29, 2025, the Federal Council opened the consultation on the exchange of information regarding OECD minimum taxation.
Memorandum of Understanding between Switzerland and the USA
On January 8, the SIF published the Memorandum of Understanding dated December 5, 2024 regarding the eligibility of certain US and Swiss pension funds to claim treaty benefits pursuant to Art. 10 para. 3 DTA CH-USA.
Memorandum of Understanding between Switzerland and France
On December 17, 2024, the SIF announced that a new memorandum of understanding had been concluded between Switzerland and France on the taxation of cross-border teleworking.
Federal Council publishes report on the application of the direct favoritism theory for withholding tax
On December 13, 2024, the Federal Council published the report in fulfillment of postulate 22.3396 WAK-N from May 2022 "Avoiding disadvantages for Swiss companies through a uniform taxation practice".
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on August 30, 2022, entitled "Restitution in International Relations - Current Practice and Problem Areas".
International transactions involving intellectual property
Workshop by Napoleão Dagnese, Balthasar Denger and Thomas Hug on the occasion of the ISIS) seminar on 27 June 2022 entitled "International transactions involving intellectual property".
