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.
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).
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 South Korea sign Protocol of Amendment to the DTA
On 17 May 2019, Switzerland and South Korea signed a Protocol of Amendment to the Double Taxation Convention (DTA) in the area of taxes on income.
Protocol of Amendment to the DTA with Ecuador enters into force
The Protocol amending the Double Taxation Convention (DTA) between Switzerland and Ecuador in the area of taxes on income and wealth entered into force on 17 April 2019.
National Council approves agreement against tax avoidance
Parliament supports the implementation of international standards against corporate tax avoidance. Following the Council of States, the National Council has also come out in favour of an agreement.
National Council does not want a code of interpretation on tax self-reports
The National Council does not consider it necessary to know how the number of voluntary reports of tax evaders with impunity has developed since 2010. It narrowly refused by 98 votes to 93 to commission the Federal Council with a report on the matter. Even the latter would have considered it useful.
National Council against report on tax evasion
The National Council does not want to know the extent to which taxes are evaded in Switzerland. On Wednesday he refused to demand a report from the Federal Council.
SIF publishes agreement on DTA between Switzerland and Colombia
On 5 March 2019, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MoU) on the Agreement between the Swiss Confederation and the Republic of Colombia on the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 26 October 2007 (DTA Switzerland-Colombia).
Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
Current cases on intercantonal and international corporate tax law
Workshop from the ISIS) seminar on 2/3 March 2020 entitled "Corporate Tax Law 2020
Structuring of real estate assets with a view to estate planning
Workshop on the occasion of the ISIS) seminar of 28 November 2019 entitled "Tax Aspects of Estate Planning for Real Estate".
Possibilities and limits of tax planning for inheritances and gifts - national and international
Workshop on the occasion of the ISIS seminar on 9/10 September 2019 entitled "Tax planning in the area of conflict between cost optimisation, tax compliance and Good citizenship - opportunities and risks".
