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.
Entry into force of the Protocol of Amendment to the DTA with Tajikistan
According to the SIF, the Protocol of Amendment to the DTA with Tajikistan entered into force on 2 November 2023 and is generally applicable from that date.
In the future, the international automatic exchange of information will also include crypto assets
In a joint declaration, around 50 countries, including Switzerland, commit themselves to the expanded international automatic exchange of information in tax matters (AEOI). The extension affects crypto assets and is scheduled to apply from January 1, 2026. By the end of June 2024, the Federal Department of Finance (FDF) will prepare a consultation draft for the implementation of the expanded AEOI.
Switzerland and Italy agree on permanent tax rules for working from home
On 10 November 2023, Federal Councillor Karin Keller-Sutter and the Italian Minister of Finance and Economy signed a declaration that permanently regulates the issue of taxation of home office for cross-border commuters.
OECD/G20 Inclusive Framework publishes new multilateral agreement to address the tax challenges of globalisation and digitalisation
On 11 October 2023, the OECD/G20 Inclusive Framework published a new multilateral agreement to address the tax challenges of globalisation and digitalisation.
Entry into force of the DTA between Switzerland and Ethiopia
On September 21, 2023, SIF announced that the DTA Switzerland - Ethiopia entered into force on August 10, 2023. The provisions are applicable for Switzerland as of January 1, 2024 and in Ethiopia as of July 8, 2024.
Switzerland and Serbia sign Protocol of Amendment to Double Taxation Agreement
On September 19, 2023, Switzerland and Serbia signed a Protocol of Amendment to the DTA, which implements the minimum standards in double taxation treaty matters.
Switzerland and Germany sign protocol of amendment to DTA
Switzerland and Germany signed the revision protocol amending the DTA of 11 August 1971 on 21 August 2023 on the fringes of the meeting of German-speaking finance ministers in Aschau im Chiemgau.
FDF publishes first report on cantonal measures in connection with the implementation of the OECD minimum tax
On August 8, 2023, the FDF published the first report on the expected impact of the implementation of the OECD minimum tax on the individual cantons as well as the planned measures of the individual cantons as of May 31, 2023.
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".
