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.
Federal Council adopts dispatch on the Protocol of Amendment to the DTA with Ukraine
At its meeting on 9 October 2019, the Federal Council approved the dispatch on the approval of a Protocol of Amendment to the Agreement to Avoid Double Taxation in the Area of Taxes on Income and Capital (DTA) between Switzerland and Ukraine. The protocol implements the minimum standards in double taxation agreements and also adapts the DTA to the current treaty policy of the two states.
Exchange of information with 75 countries on around 3.1 million financial accounts
According to the media release of the Federal Tax Administration (FTA) of 7 October 2019, the FTA has exchanged information on financial accounts with 75 countries. The exchange takes place within the framework of the global standard for automatic information exchange (AIA).
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 Iran sign Protocol of Amendment to the DTA
On 3 June 2019, Switzerland and Iran signed an amendment protocol to the double taxation agreement (DTA) in the area of taxes on income and assets.
Implement the recommendations of the Global Forum on transparency and exchange of information for tax purposes
The Council of States and the National Council have adopted the federal law implementing recommendations of the Global Forum on transparency and exchange of information for tax purposes.
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.
Current problems of intercantonal and international corporate tax law (2019)
Workshop on the occasion of the ISIS) seminar on 3/4 June 2019 entitled "News on corporate tax law
Current questions on withholding tax and stamp duties, including international issues (2019)
Workshop on the occasion of the ISIS) seminar on 3/4 June 2019 entitled "News on corporate tax law
