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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Switzerland and South Korea sign Protocol of Amendment to the DTA
On 17 May 2019, Switzerland and South Korea signed a Protocol of Amendment to the Double Taxation Convention (DTA) in the area of taxes on income.
Protocol of Amendment to the DTA with Ecuador enters into force
The Protocol amending the Double Taxation Convention (DTA) between Switzerland and Ecuador in the area of taxes on income and wealth entered into force on 17 April 2019.
SIF publishes agreement on DTA between Switzerland and Colombia
On 5 March 2019, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MoU) on the Agreement between the Swiss Confederation and the Republic of Colombia on the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 26 October 2007 (DTA Switzerland-Colombia).
National Council against report on tax evasion
The National Council does not want to know the extent to which taxes are evaded in Switzerland. On Wednesday he refused to demand a report from the Federal Council.
National Council does not want a code of interpretation on tax self-reports
The National Council does not consider it necessary to know how the number of voluntary reports of tax evaders with impunity has developed since 2010. It narrowly refused by 98 votes to 93 to commission the Federal Council with a report on the matter. Even the latter would have considered it useful.
National Council approves agreement against tax avoidance
Parliament supports the implementation of international standards against corporate tax avoidance. Following the Council of States, the National Council has also come out in favour of an agreement.
Double Taxation Convention
The Commission also follows the decision of the National Council from the last winter session and requests approval of the double taxation agreement with Brazil (18,064; 10 votes to 1 with 1 abstention) and the United Kingdom (18,062; unanimously).
Withholding tax according to DBA
The Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) has updated the overviews of the contractual limits on foreign taxes, the tax relief for Swiss dividends and interest, and the countries whose agreements contain abuse provisions.
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Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
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 securing tax planning (rulings, notifications, assurances, preliminary notices and the like), exchange of information, administrative and legal assistance
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".
