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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Memorandum of Understanding between Switzerland and France on the taxation of cross-border commuters for teleworking or home office work remains in force until the end of 2020
The State Secretariat for International Financial Matters (SIF) reported on 28 August 2020 that the provisional understanding agreement of 13 May 2020 between Switzerland and France on the taxation of frontier workers working in the home office as a result of measures to combat COVID-19 remains in force until 31 December 2020.
Federal Council adopts messages on the new DTA with Bahrain and on the amendments to the DTA with Kuwait
At its meeting on 26 August 2020, the Federal Council adopted the messages on a new double taxation agreement (DTA) with Bahrain and on the Protocol of Amendment to the DTA with Kuwait.
FTA publishes Circular Letter No. 49 "Proof of business-related expenses for foreign transactions abroad" and Circular Letter No. 50 "Inadmissibility of tax deduction of bribes paid to public officials".
On 13 July 2020, the FTA published Circular No. 49 "Evidence of business-related expenses for foreign-foreign transactions" and Circular No. 50 "Inadmissibility of the tax deduction of bribes paid to public officials". At the same time, the predecessor circulars of the same name, No. 9 of 22 June 2005 and No. 16 of 13 July 2007, are repealed.
Switzerland and Liechtenstein sign Protocol of Amendment to the Double Taxation Convention
On 14 July 2020, Switzerland and Liechtenstein signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
Switzerland and Cyprus sign Protocol of Amendment to the Double Taxation Convention
On 20 July 2020, Switzerland and Cyprus signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project with regard to double taxation agreements.
Switzerland and Malta sign Protocol of Amendment to the Double Taxation Convention
On 16 July 2020, Switzerland and Malta signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
Memorandum of Understanding between Switzerland and the USA
The State Secretariat for International Financial Matters (SIF) reports the conclusion of a memorandum of understanding between the Swiss Confederation and the United States of America concerning the rules of procedure of the arbitration procedure provided for in Art. 25 para. 6 and 7 DBA CH/USA.
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Problems with special forms of investment (trust, foundation, trust and similar) - national and international
Workshop on the occasion of the ISIS) seminar on 10-11 September 2018
Current questions on withholding tax and stamp duties, including international issues (2018)
Workshop on the occasion of the ISIS) seminar on 4-5 June 2018 entitled "Current problems and perspectives of corporate tax law".
