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.
Introduction of the OECD/G20 minimum taxation on January 1, 2024
On December 22, 2023, the Federal Council decided to levy the supplementary tax in Switzerland from January 1, 2024.
Memorandum of Understanding on the DTA between Switzerland and Liechtenstein
The State Secretariat for International Financial Matters SIF has announced the conclusion of a new Memorandum of Understanding between Switzerland and Liechtenstein.
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.
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.
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.
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.
