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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Switzerland and Armenia sign Protocol of Amendment to the Double Taxation Agreement
Switzerland and Armenia signed a Protocol of Amendment to the corresponding DTA on 12 November 2021. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements as well as the international standard in matters of information exchange.
FTA publishes final ruling on the FATCA agreement
On 19 November 2021, the Federal Tax Administration (FTA) notified the issuance of a final ruling pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Federal Councillor Ueli Maurer meets Russian Finance Minister Anton Siluanov
Federal Councillor Ueli Maurer met the Russian Finance Minister Anton Siluanov in Bern on 19 November 2021. One of the topics discussed was the revision of the existing double taxation agreement demanded by Russia.
Federal Council adopts report on relations with Italy in the financial and tax area
At its meeting on 27 October 2021, the Federal Council adopted the report on relations with Italy in the financial and tax area.
Entry into force of the double taxation agreement with Bahrain
On 05 November, SIF announced that the DTA between Switzerland and Bahrain had entered into force and that the provisions would apply from 01 January 2022.
Federal Council enacts new legal basis for the implementation of international agreements in the tax area
In the StADG, the provisions of the existing national federal law of 22 June 1951 on the implementation of federal intergovernmental agreements for the avoidance of double taxation and the ordinances based on it are taken over as far as necessary and supplemented with new provisions. It now regulates the essential points for the relief of withholding tax as well as penalty provisions in connection with the relief of withholding taxes on investment income. It also regulates how mutual agreement procedures are to be carried out domestically if the applicable agreement does not contain any provisions to the contrary.
FTA publishes final rulings on the FATCA agreement
On 22 October 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Chair of the OECD Forum on Tax Administration (FTA) and the Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) release statement on Pandora Papers
On 14 October 2021, the Chair of the OECD Forum on Tax Administration (FTA) and the Chair of its Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) issued a joint statement on the Pandora Papers.
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Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on August 30, 2022, entitled "Restitution in International Relations - Current Practice and Problem Areas".
International transactions involving intellectual property
Workshop by Napoleão Dagnese, Balthasar Denger and Thomas Hug on the occasion of the ISIS) seminar on 27 June 2022 entitled "International transactions involving intellectual property".
