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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Protocol of Amendment to the DTA between Switzerland and the United States of America comes into force
Switzerland and the United States of America exchanged the instruments of ratification of the Protocol of Amendment to their Double Taxation Convention in the area of taxes on income (DTA) in Bern on 20 September 2019. The Protocol, which came into force on the same day, represents a milestone in tax relations between Switzerland and the USA.
Federal Council adopts dispatches on the amendments to the DTAs with Ireland and Korea
At its meeting on 20 September 2019, the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Ireland and Korea. The protocols implement the minimum standards in the area of DTAs. In addition, an arbitration clause is included in the DTA with Ireland. Both messages were referred to the Federal Assembly.
Federal Supreme Court ruling of 26 July 2019 (2C_653/2018): Administrative assistance to France regarding the identity of UBS clients
The Swiss Federal Tax Administration (FTA) may provide France with information regarding the identity of UBS clients presumed to be taxable in France.
Switzerland and Ireland sign Protocol of Amendment to the DTA
Switzerland and Ireland signed a Protocol of Amendment to the Convention on the Avoidance of Double Taxation in the Field of Taxes on Income and Capital (DTA) on 13 June 2019.
Switzerland and the Netherlands sign Protocol of Amendment to the DTA
On 12 June 2019, Switzerland and the Netherlands signed a Protocol of Amendment to the Convention on the avoidance of double taxation in the area of taxes on income (DTA).
Federal Council adopts dispatch on the introduction of AIA with 19 other countries and approves audit report
At its meeting on 29 May 2019, the Federal Council opened the Dispatch on the introduction of the automatic exchange of information on financial accounts (AIA) with 19 other states and territories.
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Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Remboursement de l'impôt anticipé: pratique des anciennes réserves, liquidation remplaçante et transposition internationale étendue
Cas pratiques présentés par Stefan Oesterhelt et Raphaël Fellay lors du séminaire ISIS) du 03 novembre 2021, intitulé "Restructurations / Fusions / Acquisitions".
