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.
The Confederation regulates the implementation of the OECD minimum tax in Switzerland
In order to implement the OECD/G20 project on the taxation of the digital economy, the Federal Council proposes a supplementary tax, with 25% of the revenue going to the Confederation and 75% to the cantons and municipalities.
VAT refund to foreign companies
The Federal Administrative Court has confirmed the practice of the FTA regarding the content of the entrepreneur's certificate: This must be valid for the remuneration period (calendar year).
Federal Council adopts dispatch on AEOI with 12 other partner states
At its meeting on 18 May 2022, the Federal Council adopted the dispatch on the introduction of AEOI with 12 other partner states.
Federal Council adopts dispatch on the amendment of the double taxation agreement with Armenia
The Federal Council adopted the dispatch on the Protocol of Amendment to the DTA on 4 May 2022.
Memorandum of Understanding between Switzerland and France
On 12 April 2022, SIF notified the conclusion of a mutual agreement dated 11 April 2022 to repeal the mutual agreement on the effects of measures to combat Covid-19 under the Switzerland-Germany DTA.
Working visit by Federal Councillor Ueli Maurer to his German counterpart
Federal Councillor Ueli Maurer met the German Finance Minister Christian Lindner for a working visit on 28 March 2022. The exchange concerned, among other things, the OECD/G20 project on taxing the digital economy.
Federal Council adopts dispatch on DTA with Ethiopia
On 18 March 2022, the Federal Council adopted the dispatch on the DTA with Ethiopia. With this DTA, Switzerland is extending its network of agreements to East Africa for the first time.
Federal Council opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Cross-border restructuring
Workshop on "Cross-border Restructuring" by Patrick Schmid and Thomas Hug on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 2023.
Current cases on intercantonal and international corporate tax law (2023)
Workshop on intercantonal and international corporate tax law by René Matteotti and Philipp Betschart on the occasion of the ISIS seminar "Corporate Tax Law 2023" on June 19/20, 2023.
Seminar folder ISIS)-Seminar "Real Estate Transactions - Tax Consequences National and Cross-Border
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Real Estate Transactions - Tax Consequences National and Cross-Border" from September 12 and 13, 2022 under the direction of Julia von Ah.
