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.
FTA publishes FATCA final rulings
On 29 January 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 para. 3 lit. b FATCA Agreement.
Technical information "Withholding tax according to DTA" has been updated
The following documents have been updated:
FTA updates the publication "Tax burden in international comparison
The publication summarises the tax rates and tax ratios in various OECD countries. Among other things, it compares corporate tax rates, capital tax rates for companies, withholding tax rates, emissions and turnover taxes, VAT rates and the treatment of losses in 2020. In particular, the publication also contains various statements on the ratio of direct to indirect taxes.
FTA updates guidance on the standard for AEOI in tax matters
The FTA has updated the guidance on the standard for the automatic exchange of information (AEOI) in tax matters.
New cross-border commuter agreement between Switzerland and Italy of 23 December 2020
On 23 December 2020, Switzerland and Italy signed a new agreement on cross-border commuters, which replaces the current agreement of 1974 and now applies reciprocally.
Canton of Zurich: Tax segregation of companies with foreign permanent establishments
Section 57 para. 3 StG ZH was adapted to the corresponding provision in the law on direct federal tax with effect from 01 January 2021.
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".
