Tax avoidance through offshore structures
On Sunday evening, 4 October 2021, various media around the world simultaneously published the so-called "Pandora Papers", which once again accuse various individuals of tax evasion and tax avoidance through structures, be it in the form of foundations, trusts or companies based in so-called tax havens. There have been similar revelations before, namely in April 2016 in the "Panama Papers" and in November 2017 in the "Paradise Papers". What all these revelations have in common is that they are based on data leaks and target prominent people from politics, business, sports and entertainment with media attention. The revelations have led to an increased call for transparency and increasingly strict compliance regulations. However, the media also reveal that these offshore companies are legal structures used to optimise taxes, but not to evade them. Foundations and trusts are indeed legal structures that are usually not set up for purely tax considerations. Nevertheless, such (offshore) structures can lead to under-taxation if they are treated as fiscally transparent by the Swiss tax authorities and the founder/trustee and/or beneficiary resident in Switzerland has not declared the assets and income.
"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.
New OECD report on post-pandemic planning for tax administrations published
On 26 May 2020 the OECD published the new report "Tax Administration Responses to COVID-19: Recovery Period Planning". This third COVID-19 report addresses the main issues that tax administrations should consider when planning the recovery period under COVID-19. According to the OECD report, early planning for the resumption of entrepreneurial activity is necessary for both tax administrations and taxpayers in order to identify the most important challenges and opportunities at an early stage and to take preparatory measures.
Automatic exchange of information on financial accounts - Federal Council publishes the audit report on 33 partner states
On 20 May 2020, the Federal Council submitted the audit report on the standard-compliant implementation of the Automatic Exchange of Information to the relevant parliamentary commissions (WAK-N and WAK-S) for consultation. The report examined compliance by the partner states with the audit criteria of the Federal Decree on the Audit Mechanism of 6 December 2017, such as whether data confidentiality is guaranteed.
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).
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".
