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.
Taxation of employees in the case of cross-border work in the home office
Sarah Bühler, René Matteotti and Peter Vogt address the taxation of international employees and their home office activities. They provide an overview of the existing regulations and pay particular attention to the cross-border commuter agreements with Switzerland's neighboring countries.
Federal Council adopts dispatches on the amendments to the DTAs with Ireland and Korea
At its meeting on 20 September 2019, the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Ireland and Korea. The protocols implement the minimum standards in the area of DTAs. In addition, an arbitration clause is included in the DTA with Ireland. Both messages were referred to the Federal Assembly.
Federal Supreme Court ruling of 26 July 2019 (2C_653/2018): Administrative assistance to France regarding the identity of UBS clients
The Swiss Federal Tax Administration (FTA) may provide France with information regarding the identity of UBS clients presumed to be taxable in France.
Switzerland and Iran sign Protocol of Amendment to the DTA
On 3 June 2019, Switzerland and Iran signed an amendment protocol to the double taxation agreement (DTA) in the area of taxes on income and assets.
Implement the recommendations of the Global Forum on transparency and exchange of information for tax purposes
The Council of States and the National Council have adopted the federal law implementing recommendations of the Global Forum on transparency and exchange of information for tax purposes.
Federal Council adopts dispatch on the introduction of AIA with 19 other countries and approves audit report
At its meeting on 29 May 2019, the Federal Council opened the Dispatch on the introduction of the automatic exchange of information on financial accounts (AIA) with 19 other states and territories.
Switzerland and the Netherlands sign Protocol of Amendment to the DTA
On 12 June 2019, Switzerland and the Netherlands signed a Protocol of Amendment to the Convention on the avoidance of double taxation in the area of taxes on income (DTA).
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
Social security law
Workshop by Franziska Stadtherr and Andreas Schiek on the occasion of the ISIS) seminar on May 22, 2025 entitled "Social Security Law"
