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.
FTA publishes final rulings on the FATCA agreement
On 22 October 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Chair of the OECD Forum on Tax Administration (FTA) and the Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) release statement on Pandora Papers
On 14 October 2021, the Chair of the OECD Forum on Tax Administration (FTA) and the Chair of its Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) issued a joint statement on the Pandora Papers.
Federal Councillor Ueli Maurer at the meeting of the G20 finance ministers and the annual meeting of the IMF and World Bank
On 9 and 10 July 2021, Federal Councillor Ueli Maurer, together with SNB President Thomas Jordan, took part in the meeting of the G20 finance ministers and central bank governors.
Exchange of information with 96 countries on around 3.3 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 96 countries. The exchange takes place within the framework of the global standard on the automatic exchange of information (AEOI).
FTA publishes FATCA final rulings (III; supplement)
On 30 September 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Media release on Switzerland's position in connection with the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
On 8 October 2021, the Inclusive Framework of the OECD (including Switzerland) specified the key parameters for the future taxation of large, internationally active companies (see our article of 9 October 2021). According to a media release, Switzerland demands that the interests of small, economically strong countries be taken into account in their implementation and that legal certainty be created for the companies affected.
OECD publishes key points on the future taxation of the digitalised economy (Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy)
On 8 October 2021, the OECD published the "Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy". The document specifies the cornerstones for the future taxation of the digitalised economy on the basis of two pillars.
Memorandum of Understanding between Switzerland and France
SIF announced on 23 September 2021 that the provisional mutual agreement of 13 May 2020 between Switzerland and France on the taxation of cross-border workers who work in the home office as a result of measures taken to combat COVID-19 will remain in force until 31 December 2021.
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.
