Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
The new double taxation agreement between Italy and Liechtenstein - advantages and specific cases of application
On July 12, 2023, Liechtenstein and Italy signed a double taxation agreement (DTA). The agreement is based on the international standard of the OECD Model Tax Convention 2017, takes into account the results of the BEPS project and follows the agreement on the exchange of information (TIEA) that was concluded with Italy in 2015. The DTA increases legal certainty, leads to significant withholding tax reductions, reduces existing barriers to investment and financing and will make a decisive contribution to further strengthening cooperation between the two countries.
The definition of turnover according to the Minimum Tax Ordinance
According to the Minimum Tax Ordinance (MindStV), business units belonging to Switzerland are subject to Swiss supplementary tax if they belong to a group of companies with a turnover of at least EUR 750 million. The concept of turnover as a central prerequisite for subjective tax liability is only rudimentarily regulated in the ordinance. This article examines this concept from different perspectives with reference to various OECD/G20 documents and identifies open questions.
Taxation of spouses in international relations - tax segregation issues
In the zsis) issue of November 2019, the authors dealt with tax law stumbling blocks in the taxation of spouses in international relationships. In this article, they have focused on the tax segregation of international spouses. On the basis of a test scheme with three questions, they show that a systematic procedure is essential for correct tax segregation and that there is still a need for action here on the part of the assessment authority and the courts.
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Federal Council adopts dispatch on new cross-border commuter agreement with Italy
At its meeting on 11 August 2021, the Federal Council adopted the dispatch on the new cross-border commuter agreement between Switzerland and Italy.
Switzerland and Ethiopia sign a double taxation agreement
On 29.07.2021, Switzerland and Ethiopia signed an agreement to avoid double taxation in the area of taxes on income. Before the agreement can enter into force, it must still be approved by the parliaments of both countries.
Switzerland and Japan sign protocol of amendment to double taxation agreement
On 16 July 2021, Switzerland and Japan signed an amendment protocol to the double taxation agreement that implements the minimum standards under BEPS.
New Form 12 FL for the declaration of the insurance stamp by Liechtenstein policyholders
A new Form 12 FL concerning the self-declaration of stamp duty on insurance premiums / insurance with a foreign insurer by Liechtenstein policyholders was published on 9 July 2021.
SIF Explanatory Notes on the German Tax Relief Procedure DTA-D for Income from Rights Registered in Germany
On 02 July 2021, the State Secretariat for International Financial Matters (SIF) published explanatory notes on the German tax relief procedure DTA-D for income from rights registered in Germany.
Memorandum of Understanding with Chile
On 29 March, Switzerland and Chile concluded a mutual agreement on the amendment of the double taxation agreement.
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Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Remboursement de l'impôt anticipé: pratique des anciennes réserves, liquidation remplaçante et transposition internationale étendue
Cas pratiques présentés par Stefan Oesterhelt et Raphaël Fellay lors du séminaire ISIS) du 03 novembre 2021, intitulé "Restructurations / Fusions / Acquisitions".
