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 amending the DTA with Germany
On June 14, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Germany.
Federal Council opens consultation on the new Federal Act on the International Automatic Exchange of Information on Salary Data
The Federal Council opened the consultation procedure at its meeting on June 7, 2024. It is proposing a new law that regulates the automatic exchange of information on salary data in tax matters between Switzerland and a partner state with which an international treaty exists.
Switzerland and Italy sign permanent tax rules for working from home
On June 6, 2024, Switzerland and Italy signed a protocol of amendment to the existing cross-border commuters agreement, which permanently regulates the issue of taxation of home offices. The protocol of amendment will enter into force as soon as the corresponding approval processes in both countries have been completed and will apply retroactively from January 1, 2024.
Publication of the report "Potential for the Swiss SME economy with a connection to the EU One-Stop-Shop for VAT settlement"
At its meeting on May 31, 2024, the Federal Council adopted the report in fulfillment of postulate 22.3384 of the WAK-N of April 11, 2024.
Federal Council opens consultation on extending the international automatic exchange of information in tax matters to crypto assets
The extension concerns the new AEOI on crypto assets and the amendment to the standard for AEOI on financial accounts and is to apply from January 1, 2026.
Federal Council adopts dispatch on the amendment of the DTA with Serbia
On May 1, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Serbia.
OECD clarifies the commentary on Article 26 (exchange of information)
On February 19, 2024, the OECD Council updated the commentary on Article 26 of the OECD Model Tax Convention. It was clarified that information received in the context of administrative tax assistance can also be used in relation to unnamed persons.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Current cases on intercantonal and international corporate tax law (2024)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current cases on intercantonal and international corporate tax law"
Special issues in trust and foundation structures
Workshop on "Special Issues in Trust and Foundation Structures" by Andrea Opel and Stefan Oesterhelt on the occasion of the ISIS seminar "Structuring Private Assets by Means of Trusts or Foundations" on October 31, 2023.
ISIS) seminar folder "Corporate Restructuring" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Corporate Restructuring" of August 29, 2023 under the direction of René Schreiber.
