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.
Switzerland and Ethiopia sign a double taxation agreement
On 29.07.2021, Switzerland and Ethiopia signed an agreement to avoid double taxation in the area of taxes on income. Before the agreement can enter into force, it must still be approved by the parliaments of both countries.
Switzerland and Japan sign protocol of amendment to double taxation agreement
On 16 July 2021, Switzerland and Japan signed an amendment protocol to the double taxation agreement that implements the minimum standards under BEPS.
New Form 12 FL for the declaration of the insurance stamp by Liechtenstein policyholders
A new Form 12 FL concerning the self-declaration of stamp duty on insurance premiums / insurance with a foreign insurer by Liechtenstein policyholders was published on 9 July 2021.
SIF Explanatory Notes on the German Tax Relief Procedure DTA-D for Income from Rights Registered in Germany
On 02 July 2021, the State Secretariat for International Financial Matters (SIF) published explanatory notes on the German tax relief procedure DTA-D for income from rights registered in Germany.
Memorandum of Understanding with Chile
On 29 March, Switzerland and Chile concluded a mutual agreement on the amendment of the double taxation agreement.
FTA publishes notices on FATCA group requests (June 2021)
On 28 June 2021, the Federal Tax Administration (FTA) published FATCA group requests pursuant to Article 12 paragraph 1 of the FATCA Act.
Consultation agreement between Switzerland and Germany
On 22 June 2021, Germany and Switzerland announced that the mutual agreement on the taxation of international workers would be extended until 30 September 2021. The parties will then consult again in due course.
Mutual agreement on arbitration pursuant to Art. 24, para. 5 of the DTA with the United Kingdom
On 16 June 2021, Switzerland and the United Kingdom concluded a mutual agreement on the conduct of arbitration proceedings in accordance with Art. 24 para. 5 of the DTA between Switzerland and the United Kingdom.
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"
