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.
FTA publishes notices on FATCA group requests (June 2021)
On 28 June 2021, the Federal Tax Administration (FTA) published FATCA group requests pursuant to Article 12 paragraph 1 of the FATCA Act.
Consultation agreement between Switzerland and Germany
On 22 June 2021, Germany and Switzerland announced that the mutual agreement on the taxation of international workers would be extended until 30 September 2021. The parties will then consult again in due course.
Mutual agreement on arbitration pursuant to Art. 24, para. 5 of the DTA with the United Kingdom
On 16 June 2021, Switzerland and the United Kingdom concluded a mutual agreement on the conduct of arbitration proceedings in accordance with Art. 24 para. 5 of the DTA between Switzerland and the United Kingdom.
FTA - Instruction on the correct submission of applications for the refund of foreign withholding tax to collective investment schemes
On 17 June 2021, the FTA published the new directive on how to submit applications for the refund of foreign withholding tax to collective investment schemes.
Memorandum of Understanding between France and Switzerland
On 16 June 2021, France and Switzerland announced that the Memorandum of Understanding on the taxation of international workers would be extended until 30 September 2021.
Strengthening Switzerland as a business location in the context of OECD work
The Federal Council has taken note of the status of the OECD/G20 work on global corporate taxation.
Mutual agreement between Switzerland and the USA on withholding tax exemption for pension plans
The Protocol of Amendment to the Double Taxation Treaty between Switzerland and the USA, which was approved on 17 July 2019, provides that dividends paid to tied pension institutions (e.g. pillar 3a) will be exempt from withholding tax from 1 January 2020, provided that they do not control the US company paying the dividends.
Remboursement de l'impôt anticipé: pratique des anciennes réserves, liquidation remplaçante et transposition internationale étendue
Cas pratiques présentés par Stefan Oesterhelt et Raphaël Fellay lors du séminaire ISIS) du 03 novembre 2021, intitulé "Restructurations / Fusions / Acquisitions".
Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
