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.
Home Office - Tax treatment in the cross-border area
Today, many tasks can be done from anywhere. The traditional workplace in the office has had its day. A telecommuting job at home brings advantages for both sides: The employer saves the costs of renting the room, the employee saves the way to the office. The following article examines the question of whether working from home can give rise to a tax permanent establishment in cross-border international situations. For the purposes of this paper, "home office" means a room or rooms which are located in the employee's home and which are used, at least in part, not only for residential purposes but also for work purposes.
Development of case law on the interpretation of the DTA Germany/Switzerland in 2013
The following contribution presents the case law of the German tax courts from 2013 with regard to 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.
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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.
Switzerland and Northern Macedonia sign Protocol of Amendment to the Double Taxation Agreement
On 19 May 2021, a Protocol of Amendment to the DTA Switzerland - Northern Macedonia was signed, which implements the minimum standards in DTA matters.
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