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.
FDF publishes first report on cantonal measures in connection with the implementation of the OECD minimum tax
On August 8, 2023, the FDF published the first report on the expected impact of the implementation of the OECD minimum tax on the individual cantons as well as the planned measures of the individual cantons as of May 31, 2023.
Cross-border commuter agreement with Italy has entered into force
On July 19, 2023, SIF announced that the new cross-border commuter agreement with Italy and an amending protocol to the DTA entered into force on July 17, 2023. The provisions are applicable as of January 1, 2024.
Memorandum of Understanding between Switzerland and France
On July 6, 2023, SIF announced that Switzerland and France have agreed on a common interpretation of the 10-day rule for business trips that qualify as home offices under the December 22, 2022 Memorandum of Understanding.
Switzerland and France sign an additional agreement to the bilateral double taxation agreement
On June 27, 2023, an additional agreement to the bilateral DTA was signed in Paris, which contains new and permanent taxation rules for home office income.
Federal Council adopts dispatch on the amendment of the double taxation agreement with the United Arab Emirates
On May 4, 2022, the Federal Council adopted the Dispatch on the Protocol of Amendment to the DTA with UAE.
Entry into force of the Protocol of Amendment to the DTA with Armenia
According to SIF's notification, the Protocol of Amendment to the DTA with Armenia entered into force on May 2, 2023. Most of the amendments are applicable as of January 1, 2024.
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.
Cross-border restructuring
Workshop on "Cross-border Restructuring" by Patrick Schmid and Thomas Hug on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 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.