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.
Federal Council creates national basis for the taxation of teleworking by cross-border commuters
At its meeting on March 1, 2024, the Federal Council adopted the dispatch on the taxation of teleworking in international relations.
Introduction of the OECD/G20 minimum taxation on January 1, 2024
On December 22, 2023, the Federal Council decided to levy the supplementary tax in Switzerland from January 1, 2024.
Memorandum of Understanding on the DTA between Switzerland and Liechtenstein
The State Secretariat for International Financial Matters SIF has announced the conclusion of a new Memorandum of Understanding between Switzerland and Liechtenstein.
Switzerland and Angola sign a double taxation agreement
On November 30, 2023, Switzerland and Angola signed an agreement to avoid double taxation (DTA) in the area of taxes on income.
Consultation opened on lowering the tax-free limit for travel
In implementation of the 19.3975 Motion FK-N "Improving tax justice in the flow of goods in local border traffic", the FDF is planning to reduce the tax-free limit for goods in tourist traffic from CHF 300 to CHF 150 per person. The consultation on this has been opened.
Memoranda of Understanding between Switzerland and Italy - Telework 2023 / 2024-2025
On November 28, 2023, the SIF reported that the competent authorities in Italy and Switzerland had concluded two memoranda of understanding.
Federal Council adopts dispatch on amending DTA with Slovenia
On 22 November 2023, the Federal Council adopted the dispatch on amending the DTA with Slovenia.
Federal Council adopts dispatch on the supplementary agreement to the DTA with France
On 22 November 2023, the Federal Council adopted the dispatch on the approval and implementation of an additional agreement to the DTA with France, which regulates in particular the taxation of cross-border teleworking to the extent of up to 40% of working hours per year.
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".
