Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
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.
Memorandum of Understanding between Switzerland and France
SIF announced on 23 September 2021 that the provisional mutual agreement of 13 May 2020 between Switzerland and France on the taxation of cross-border workers who work in the home office as a result of measures taken to combat COVID-19 will remain in force until 31 December 2021.
Consultation agreement between Switzerland and Germany
SIF announced on 07 September 2021 that the consultation agreement of 11 June 2020 between Switzerland and Germany concerning the taxation of cross-border workers during the COVID-19 pandemic will not be terminated until at least 31 December 2021.
Application of the most-favoured-nation clause according to the protocol of the double taxation agreement between Switzerland and India
In its communication of 13 August 2021, the State Secretariat for International Financial Matters (SIF) provides information on the changes to dividend taxation due to the application of the most-favoured-nation clause in the DTA CH-IN.
Federal Council adopts dispatch on new cross-border commuter agreement with Italy
At its meeting on 11 August 2021, the Federal Council adopted the dispatch on the new cross-border commuter agreement between Switzerland and Italy.
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.
ISIS seminar folder "Gratuitous transfer of assets under tax law"
All documents from the ISIS) seminar "Gratuitous transfer of assets in tax law" from October 28, 2025 under the direction of Peter Mäusli-Allenspach in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
Practical examples of cross-border issues in relation to Germany
Case studies, slides and detailed solution notes from the workshop held by Hanna Brozzo and Iring Christopeit on October 28, 2025 on the occasion of the ISIS seminar "Gratuitous asset transfers in tax law".
