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.
Consultation agreement with Germany on cross-border workers and state benefits extended
The State Secretariat for International Financial Matters (SIF) reported on 3 December 2020 that the consultation agreement between Switzerland and Germany on the taxation of cross-border commuters and treatment of state support benefits will remain in force until 31 March 2021 (see our article of 13 June 2020).
Mutual agreement with France on cross-border taxation of home office workers extended
The State Secretariat for International Financial Matters (SIF) reported on 3 December 2020 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 March 2021.
ESTV - Agreement on mutual understanding between Switzerland and Austria
The State Secretariat for International Financial Matters SIF reported on 12 November 2020 the conclusion of a new Memorandum of Understanding between Switzerland and Austria on the implementation of Article 25 paragraph 5 (arbitration).
Federal Council adopts dispatches on the amendments to the DTAs with Liechtenstein, Malta and Cyprus
On 11 November 2020 the Federal Council adopted the Dispatches on the Protocols of Amendment to the double taxation agreements (DTAs) with Liechtenstein, Malta and Cyprus. The protocols implement the DTA minimum standards.
Federal Council puts revised law and ordinance on AIA into force
In the course of an examination of the Global Forum's audit of Switzerland, recommendations were made. The amendments take these into account and include in particular the abolition of the exemption for condominiums communities and an adjustment of the applicable due diligence obligations.
Federal Council adopts dispatch on the Federal Act on the Implementation of International Agreements in the Tax Field
On 4 November 2020, the Federal Council adopted the dispatch on the totally revised Federal Act of 1951 on the Implementation of Interstate Agreements of the Confederation for the Avoidance of Double Taxation (new: StADG).
FTA - Memorandum of Understanding between Switzerland and Liechtenstein
On 27 October 2020, the State Secretariat for International Financial Matters SIF reported the conclusion of a new memorandum of understanding between Switzerland and Liechtenstein on the effects of measures to combat COVID-19 on the treatment of cross-border commuters under the DTA.
Federal Councillor Ueli Maurer meets with Ticino government on the agreement with Italy on cross-border commuters
On 16 October 2020, Federal Councillor Ueli Maurer met with the Cantonal Government of Ticino and informed about the latest exchange with the Italian Ministry of Finance on the agreement with Italy on the taxation of cross-border commuters.
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".
