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.
Federal Council repeals the transitional provision in the Ordinance on the International Automatic Exchange of Information in Tax Matters
At its meeting on 7 November 2018, the Federal Council decided to repeal the transitional provision on the term "participating states" in the Ordinance on the International Automatic Exchange of Information in Tax Matters as of 1 January 2019. This will implement an international requirement.
Commission suspends consultation on double taxation agreement with Saudi Arabia
Following the murder of the journalist Khashoggi, the Commission has decided to suspend discussion of this agreement until the Federal Council has thoroughly reviewed Switzerland's relations with Saudi Arabia.
First exchange of information on around 2 million financial accounts
The Federal Tax Administration (FTA) has exchanged information on financial accounts for the first time. The exchange takes place within the framework of the global standard for automatic information exchange (AIA).
Federal Council adopts dispatch on double taxation agreement with Brazil
On 5 September 2018 the Federal Council adopted the dispatch on the double taxation agreement (DTA) in the area of income taxes with Brazil. This is the first DTA between Switzerland and Brazil. The agreement was signed in Brasilia on 3 May 2018 and will come into force following approval by the parliaments of both countries.
No extension of mutual assistance for fiscal offences
Following its decision not to revise the law on fiscal offences, the Federal Council has also decided not to extend mutual assistance in fiscal offences. In particular, it would put the Swiss tax authorities at a disadvantage compared to foreign tax authorities. The Federal Council took this decision at its meeting on 29 August 2018.
Federal Council adopts dispatch on the BEPS Convention
On 22 August 2018, the Federal Council adopted the dispatch on the multilateral agreement on the implementation of measures to prevent base erosion and profit shifting (BEPS). The message was referred to the Federal Councils.
FTA sends country-specific reports from multinational corporations for the first time (June 2018)
At the end of June, the Swiss Federal Tax Administration (FTA) will for the first time send country-specific reports from multinational corporations to 35 partner states. The reports are sent as part of the so-called country-by-country reporting. By the end of June, the FTA will have sent a total of 109 reports to 35 countries. The country-specific reports contain, among other things, information on the worldwide distribution of income, the taxes paid and the most important economic activities of the Group in various countries. The content is confidential and subject to the principle of speciality.
Regulation on international administrative assistance (9 May 2018)
At its meeting on 9 May 2018, the Federal Council adopted the dispatch on the approval of the agreements on the automatic exchange of information on financial accounts (AIA) with Singapore and Hong Kong. With the same dispatch, the Federal Council is proposing to parliament the introduction of the AIA with other financial centres. In October 2017, the Federal Council decided to apply the agreements with Singapore and Hong Kong provisionally as of 1 January 2018 and to exchange account information with these countries for the first time in autumn 2019. This was the only way to ensure that the timetable could be adhered to. With the current proposal, the Federal Council is now asking the Federal Assembly for authorisation to ratify the two agreements. At the same time, the Federal Council is proposing as an option to implement the AIA with Singapore and Hong Kong based on the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of information on financial accounts. This solution takes into account the latest developments in Singapore and Hong Kong and would allow the AIA to be implemented on a multilateral basis.
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"
