"Mother-daughter" arrangement between Italy and Switzerland
Opinion No. 537 of 6 August 2021 of the Italian tax authorities, described in this article, is a further sign of the "normalisation" of income tax relations between Italy and Switzerland.
Refund of withholding tax in international relations
The refund of withholding tax on dividends from Swiss companies by foreign shareholders can only be made on the basis of a double taxation agreement between Switzerland and the country of residence of the claimant. In order to claim relief from withholding tax under the applicable double taxation treaty, the residence of the claimant must be confirmed by the foreign tax authorities.
Transfer of the registered office to Switzerland - A case for the old reserve practice?
The problem of old reserves has become an integral part of daily tax consulting practice in Switzerland. The corresponding problem will be examined in this article on the basis of a transfer of the registered office of a foreign company to Switzerland. Here, too, the Federal Tax Administration (FTA) initially assumed that the "old reserves" brought into Switzerland were subject to Swiss abuse practice without restriction.
Place of actual administration in the age of digitalisation & home office
Since the concept of the place of actual administration was incorporated into the law in 1951, digitisation has progressed in great strides. The author explores the question of the extent to which, in the age of home offices and video conferencing via the internet, criteria such as office space, lack of staff, lack of telephone accessibility and address redirection are still contemporary and whether the place of actual administration can still be determined geographically at all in the face of increasing mobility.
Consultation agreement with France on the taxation of frontier workers in the case of tele- or home-office work
On 14 May 2020, the State Secretariat for International Financial Matters SIF reported the conclusion of a new consultation agreement between Switzerland and France on the taxation of cross-border commuters in the case of teleworking or home office work.
Consultation agreement with Germany on the taxation of railway staff
On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
SIF publishes peer review report of the Global Forum
On 6 April 2020, the State Secretariat for International Financial Matters (SIF) published the peer review report on the exchange of information upon request for tax purposes.
FTA - Key figures on international administrative assistance
On 27 February 2020, the Federal Tax Administration updated the key figures on international administrative assistance in 2019.
OECD publishes report on transfer prices in financial transactions
On 11 February 2020, the Organisation for Economic Cooperation and Development (OECD) published a report containing guidelines on the transfer pricing aspects of financial transactions.
OECD publishes statement on taxation of multinational companies
On 31 January 2020, the Organisation for Economic Cooperation and Development (OECD) published a statement on taxation of multinational (digital) companies, according to which an agreement should be in place by the end of 2020 (see also taxlawblog contributions of 12 October 2019 and 9 November 2019).
SIF updates list of DTAs with abuse provisions
On 17 January 2020, the Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) updated the list of agreements with abuse provisions.
Federal Council opens consultation on the Federal Act on the Implementation of International Tax Treaties
At its meeting on 13 December 2019, the Federal Council opened the consultation process on the Federal Act on the Implementation of International Agreements in the Tax Field (new StADG). The consultation period will last until 27 March 2020.
Current cases on intercantonal and international corporate tax law (2021)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on 14/15 and 21/22 June 2021 entitled "Corporate Tax Law 2021".
Reimbursement in international circumstances - current practice and problem areas
Workshop on the occasion of the ISIS) seminar on 21 September 2020 entitled "Practical cases on withholding tax and outlook on current developments".
