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.
.jpg)
.jpg)
Switzerland and Angola sign a double taxation agreement
On November 30, 2023, Switzerland and Angola signed an agreement to avoid double taxation (DTA) in the area of taxes on income.
Consultation opened on lowering the tax-free limit for travel
In implementation of the 19.3975 Motion FK-N "Improving tax justice in the flow of goods in local border traffic", the FDF is planning to reduce the tax-free limit for goods in tourist traffic from CHF 300 to CHF 150 per person. The consultation on this has been opened.
Memoranda of Understanding between Switzerland and Italy - Telework 2023 / 2024-2025
On November 28, 2023, the SIF reported that the competent authorities in Italy and Switzerland had concluded two memoranda of understanding.
Entry into force of the Protocol of Amendment to the DTA with Tajikistan
According to the SIF, the Protocol of Amendment to the DTA with Tajikistan entered into force on 2 November 2023 and is generally applicable from that date.
Federal Council adopts dispatch on the supplementary agreement to the DTA with France
On 22 November 2023, the Federal Council adopted the dispatch on the approval and implementation of an additional agreement to the DTA with France, which regulates in particular the taxation of cross-border teleworking to the extent of up to 40% of working hours per year.
Federal Council adopts dispatch on amending DTA with Slovenia
On 22 November 2023, the Federal Council adopted the dispatch on amending the DTA with Slovenia.
In the future, the international automatic exchange of information will also include crypto assets
In a joint declaration, around 50 countries, including Switzerland, commit themselves to the expanded international automatic exchange of information in tax matters (AEOI). The extension affects crypto assets and is scheduled to apply from January 1, 2026. By the end of June 2024, the Federal Department of Finance (FDF) will prepare a consultation draft for the implementation of the expanded AEOI.
.jpg)
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 securing tax planning (rulings, notifications, assurances, preliminary notices and the like), exchange of information, administrative and legal assistance
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".
