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.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Federal Council adopts dispatch on the new Federal Act on the International Automatic Exchange of Information on Salary Data
At its meeting on May 14, 2025, the Federal Council adopted the dispatch on the international automatic exchange of information on salary data.
Federal Council wants to amend the minimum taxation ordinance
At its meeting on April 30, 2025, the Federal Council opened the consultation on an amendment to the Minimum Tax Ordinance (MindStV). The Minimum Tax Ordinance is to be supplemented by the rules on the international reporting obligation (GloBE Information Return, GIR).
Tax relief for Norway
On April 24, 2025, the SIF published an overview of the effects of the agreement on tax relief for Norway.
Tax relief for various countries
On April 7, 2025, the SIF updated the overview of the effects of the agreement (extent of relief) for various countries.
Switzerland and Zimbabwe sign a double taxation agreement
On March 19, 2025, Switzerland and Zimbabwe signed an agreement on the avoidance of double taxation (DTA) in the area of income taxes in Harare.
Memorandum of Understanding between Switzerland and Italy - Administrative cooperation
On March 19, 2025, the SIF reported that the competent authorities of Switzerland and Italy, in accordance with Art. 7 para. 1 of the Agreement of December 23, 2020 between Switzerland and Italy on the taxation of cross-border commuters, have defined the details of the application of administrative cooperation by mutual agreement.
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"
