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.
The Liechtenstein private law establishment with divided or undivided capital
The Liechtenstein private law establishment is a very versatile and flexible legal form which is unknown under Swiss company law and cannot generally be assigned to corporations or foundations. The article deals with the "establishment" as a special feature of Liechtenstein company law.
Taxation of spouses in international relations
An "international" spouse relationship from a tax law perspective exists if only one spouse is subject to unlimited tax liability in Switzerland, while the other spouse has no or only limited tax liability in Switzerland. It must also be a legally and factually unseparated marriage. The taxation of such "international" spousal relationships is opposed by the addition of factors as prescribed by law. However, according to the established case law of the Federal Supreme Court, the latter - unlike in intercantonal relations - cannot create any tax liability in Switzerland.
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Memorandum of Understanding between Switzerland and France on the taxation of cross-border commuters for teleworking or home office work remains in force until the end of 2020
The State Secretariat for International Financial Matters (SIF) reported on 28 August 2020 that the provisional understanding agreement of 13 May 2020 between Switzerland and France on the taxation of frontier workers working in the home office as a result of measures to combat COVID-19 remains in force until 31 December 2020.
Federal Council adopts messages on the new DTA with Bahrain and on the amendments to the DTA with Kuwait
At its meeting on 26 August 2020, the Federal Council adopted the messages on a new double taxation agreement (DTA) with Bahrain and on the Protocol of Amendment to the DTA with Kuwait.
FTA publishes Circular Letter No. 49 "Proof of business-related expenses for foreign transactions abroad" and Circular Letter No. 50 "Inadmissibility of tax deduction of bribes paid to public officials".
On 13 July 2020, the FTA published Circular No. 49 "Evidence of business-related expenses for foreign-foreign transactions" and Circular No. 50 "Inadmissibility of the tax deduction of bribes paid to public officials". At the same time, the predecessor circulars of the same name, No. 9 of 22 June 2005 and No. 16 of 13 July 2007, are repealed.
Switzerland and Liechtenstein sign Protocol of Amendment to the Double Taxation Convention
On 14 July 2020, Switzerland and Liechtenstein signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
Switzerland and Cyprus sign Protocol of Amendment to the Double Taxation Convention
On 20 July 2020, Switzerland and Cyprus signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project with regard to double taxation agreements.
Switzerland and Malta sign Protocol of Amendment to the Double Taxation Convention
On 16 July 2020, Switzerland and Malta signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
Memorandum of Understanding between Switzerland and the USA
The State Secretariat for International Financial Matters (SIF) reports the conclusion of a memorandum of understanding between the Swiss Confederation and the United States of America concerning the rules of procedure of the arbitration procedure provided for in Art. 25 para. 6 and 7 DBA CH/USA.
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Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
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".
