Tax-exempt legal entities for profit and supplementary taxes in Switzerland - A legal comparison
Not only the federal, cantonal and communal taxes on profits (DBG, StHG), but also the supplementary taxes (GloBE model regulations, MindStV) recognize the concept of subjective tax exemption for legal entities. The regulations are basically congruent, but there are several case constellations of practical relevance in which the supplementary taxes override the profit tax exemption (e.g. cantonal banks, health insurance companies, newly established companies). The author therefore sees a need for action on the part of legislators and tax authorities.
Taxation of spouses in international relationships - Federal Supreme Court ruling of September 23, 2024 Prejudice on tax separation issues
In its ruling of September 23, 2024, the Federal Supreme Court issued a long-awaited precedent on the issue of international tax differentiation of debts and debt interest in the case of international spouses and revised its ruling of March 2023 on the international transfer of maintenance payments to the divorced spouse. What does this precedent mean for practice and how should other exciting practical cases be handled?
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.
FTA publishes circular "Instruction sheets and DTA overviews for withholding tax".
With the circular Leaflets for Withholding Tax and Overviews of Double Taxation Treaties dated January 27, 2023, the FTA informs about changes in the double taxation treaties (DTAs), the various withholding tax leaflets and the related DTA overviews as of January 1, 2023.
Consultation agreement between Switzerland and Germany concerning withholding taxes
The State Secretariat for International Financial Matters SIF announces that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the procedure for relief from German withholding taxes on dividends, interest and royalties under the double taxation agreement between Switzerland and Germany.
Memorandum of Understanding between Switzerland and France on cross-border home office
According to media releases from the Federal Tax Administration (FTA) and the Federal Department of Finance (FDF) dated December 22, 2022, Switzerland and France have agreed on a solution for the taxation of home office income, which will apply from January 1, 2023. According to this, up to 40 percent of the working time per year can be performed in the home office without this having any impact on the state of taxation of income from employment - especially for cross-border commuters.
Home office - No extension of the mutual agreement between Switzerland and Italy
On December 22, 2022, the State Secretariat for International Financial Matters (SIF) announced that the mutual agreement between Switzerland and Italy of June 18-19, 2020, which includes, among other things, exceptional and temporary special rules for home office taxation, will remain in force only until January 31, 2023.
Entry into force of the Protocol of Amendment to the DTA with Japan
The Protocol of Amendment to the Double Taxation Agreement (DTA) between Switzerland and Japan has entered into force. With the exception of individual provisions, most of the amendments are applicable as of January 1, 2023.
Federal Council adopts dispatch on the amendment of the DTA with Tajikistan
On 16 November 2022, the Federal Council adopted the dispatch on the amending protocol to the DTA with Tajikistan. The protocol implements the minimum standards from the BEPS project.
Switzerland and United Arab Emirates sign protocol of amendment to DTA
Switzerland and the United Arab Emirates signed a protocol amending the agreement for the avoidance of double taxation (DTA) in the area of taxes on income in Abu Dhabi on November 5, 2022. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
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".
