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.
Tax rulings - Swiss success model at risk?
Tax rulings are omnipresent in Swiss tax consulting. With the StAhiV, they have been incorporated into Swiss legislation for the first time as of 1 January 2017 and are referred to there as "preliminary tax assessments", about which other states must be informed in certain situations. Recently, the courts have also been increasingly concerned with questions relating to tax rulings.
Development of case law on the interpretation of the DTA Germany - Switzerland in 2014
The following contribution presents the 2014 case law of the German and Swiss tax courts regarding the application and interpretation of the Convention between the Federal Republic of Germany and the Swiss Confederation for the Avoidance of Double Taxation in the Field of Taxes on Income and Capital of 11 August 1971 (hereinafter referred to as the DTA). This contribution is a continuation of the overviews published in previous years on the development of case law on the interpretation of the DBA Germany/Switzerland.
Consultation agreement between Switzerland and Germany
SIF announced on 07 September 2021 that the consultation agreement of 11 June 2020 between Switzerland and Germany concerning the taxation of cross-border workers during the COVID-19 pandemic will not be terminated until at least 31 December 2021.
Application of the most-favoured-nation clause according to the protocol of the double taxation agreement between Switzerland and India
In its communication of 13 August 2021, the State Secretariat for International Financial Matters (SIF) provides information on the changes to dividend taxation due to the application of the most-favoured-nation clause in the DTA CH-IN.
Federal Council adopts dispatch on new cross-border commuter agreement with Italy
At its meeting on 11 August 2021, the Federal Council adopted the dispatch on the new cross-border commuter agreement between Switzerland and Italy.
Switzerland and Ethiopia sign a double taxation agreement
On 29.07.2021, Switzerland and Ethiopia signed an agreement to avoid double taxation in the area of taxes on income. Before the agreement can enter into force, it must still be approved by the parliaments of both countries.
Switzerland and Japan sign protocol of amendment to double taxation agreement
On 16 July 2021, Switzerland and Japan signed an amendment protocol to the double taxation agreement that implements the minimum standards under BEPS.
New Form 12 FL for the declaration of the insurance stamp by Liechtenstein policyholders
A new Form 12 FL concerning the self-declaration of stamp duty on insurance premiums / insurance with a foreign insurer by Liechtenstein policyholders was published on 9 July 2021.
SIF Explanatory Notes on the German Tax Relief Procedure DTA-D for Income from Rights Registered in Germany
On 02 July 2021, the State Secretariat for International Financial Matters (SIF) published explanatory notes on the German tax relief procedure DTA-D for income from rights registered in Germany.
