Partnerships and other personal legal entities for supplementary taxes
It is not uncommon for privately held groups to have partnerships and other personal legal entities such as trusts, foundations or private individuals linked by shareholders' agreements at the top of the structure. This article analyzes how such legal entities are to be treated for Swiss and international supplementary taxes and to what extent the provisions of Swiss income and profit tax law have an influence on this.
Cross-border commuter regulation Switzerland-France
The home office has fundamentally changed cross-border taxation - also in the relationship between Switzerland and France. New rules have applied to French cross-border commuters since 2023, which allow more flexibility but also place greater demands on employers and employees. This article provides a concise overview of the current tax framework and shows what should be paid particular attention to.
Tax-exempt legal entities for profit and supplementary taxes in Switzerland - A legal comparison
Not only the federal, cantonal and communal taxes on profits (DBG, StHG), but also the supplementary taxes (GloBE model regulations, MindStV) recognize the concept of subjective tax exemption for legal entities. The regulations are basically congruent, but there are several case constellations of practical relevance in which the supplementary taxes override the profit tax exemption (e.g. cantonal banks, health insurance companies, newly established companies). The author therefore sees a need for action on the part of legislators and tax authorities.
Taxation of spouses in international relationships - Federal Supreme Court ruling of September 23, 2024 Prejudice on tax separation issues
In its ruling of September 23, 2024, the Federal Supreme Court issued a long-awaited precedent on the issue of international tax differentiation of debts and debt interest in the case of international spouses and revised its ruling of March 2023 on the international transfer of maintenance payments to the divorced spouse. What does this precedent mean for practice and how should other exciting practical cases be handled?
Update of the overview of the effects of the agreement (extent of relief) concerning Australia
The State Secretariat for International Financial Matters (SIF) has updated the overview of the effects of the agreement (extent of relief) concerning Australia.
OECD publishes Transfer Pricing Guidelines
On 20 January 2022, the OECD published the latest version 2022 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Federal Council opens consultation on the automatic exchange of information with twelve other partner states
At its meeting on 3 December 2021, the Federal Council opened the consultation on the introduction of the automatic exchange of information on financial accounts (AEOI) with twelve additional states and territories.
Memorandum of Understanding between Switzerland and France
On 7 December, SIF announced that the mutual agreement between Switzerland and France of 13 May 2020 on the taxation of cross-border workers who work in the home office as a result of measures to combat Covid-19 will remain in force until 31 March 2022. Unless terminated by either party, it will then remain in force until 30 June 2022.
Entry into force of the amending protocols of three DTAs (Cyprus, Malta, Liechtenstein)
The protocols amending the DTAs with Cyprus, Malta and Liechtenstein have entered into force. Most of the amendments apply from 1 January 2022, but some already apply from the date of entry into force.
FTA publishes notices on FATCA group requests
On 30 November 2021, the Federal Tax Administration (FTA) published FATCA group requests pursuant to Article 12 paragraph 1 of the FATCA Act.
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"
Appeal proceedings taking into account intercantonal and international aspects (2 parts)
Workshop by Ruth Bloch-Riemer and Toni Hess on the occasion of the ISIS) seminar on May 5, 2025 entitled "Appeal procedures taking into account intercantonal and international aspects (2 parts)"
