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.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
FTA publishes circular "Instruction sheets and DTA overviews for withholding tax".
With the circular Leaflets for Withholding Tax and Overviews of Double Taxation Treaties dated January 27, 2023, the FTA informs about changes in the double taxation treaties (DTAs), the various withholding tax leaflets and the related DTA overviews as of January 1, 2023.
Consultation agreement between Switzerland and Germany concerning withholding taxes
The State Secretariat for International Financial Matters SIF announces that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the procedure for relief from German withholding taxes on dividends, interest and royalties under the double taxation agreement between Switzerland and Germany.
Memorandum of Understanding between Switzerland and France on cross-border home office
According to media releases from the Federal Tax Administration (FTA) and the Federal Department of Finance (FDF) dated December 22, 2022, Switzerland and France have agreed on a solution for the taxation of home office income, which will apply from January 1, 2023. According to this, up to 40 percent of the working time per year can be performed in the home office without this having any impact on the state of taxation of income from employment - especially for cross-border commuters.
Home office - No extension of the mutual agreement between Switzerland and Italy
On December 22, 2022, the State Secretariat for International Financial Matters (SIF) announced that the mutual agreement between Switzerland and Italy of June 18-19, 2020, which includes, among other things, exceptional and temporary special rules for home office taxation, will remain in force only until January 31, 2023.
Entry into force of the Protocol of Amendment to the DTA with Japan
The Protocol of Amendment to the Double Taxation Agreement (DTA) between Switzerland and Japan has entered into force. With the exception of individual provisions, most of the amendments are applicable as of January 1, 2023.
Federal Council adopts dispatch on the amendment of the DTA with Tajikistan
On 16 November 2022, the Federal Council adopted the dispatch on the amending protocol to the DTA with Tajikistan. The protocol implements the minimum standards from the BEPS project.
Switzerland and United Arab Emirates sign protocol of amendment to DTA
Switzerland and the United Arab Emirates signed a protocol amending the agreement for the avoidance of double taxation (DTA) in the area of taxes on income in Abu Dhabi on November 5, 2022. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
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.