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.
Taxation of international workers during the Covid 19 pandemic
René Matteotti, Peter Vogt and Natalja Ezzaini examine how the Swiss authorities dealt with the tax issues that arose as a result of the Covid 19 pandemic, which involved international employees and their work in home offices.
Tax aspects of pension assets of internationally mobile employees
Employees are more mobile than ever. As a result, they often have occupational and private pension assets in several countries. The tax situation becomes confusing at the latest when a cross-border transfer or payment of these pension assets to the beneficiaries is to take place. This article first introduces the basics and presents the respective tax consequences in Switzerland with regard to the payout from the foreign pension forms on the basis of two cross-border practical examples.
STAF transitional rules from an international perspective
Developments in international tax law have increased rapidly in recent years. The BEPS project to combat base erosion and profit shifting (BEPS), initiated by the OECD and the G20 countries, was the main trigger for this unprecedented dynamic. With a comprehensive package of measures consisting of 15 action points, the aim is to take international action against harmful tax competition and aggressive tax structuring and thus prevent undesirable profit reduction and profit shifting.
Federal Council adopts dispatch on the exchange of information on OECD minimum taxation
At its meeting on September 12, 2025, the Federal Council adopted the dispatch on the approval of the international legal basis for the exchange of information for OECD minimum taxation.
Federal Council opens consultation on AEOI with 8 other partner states
At its meeting on August 13, 2025, the Federal Council opened the consultation on the introduction of the automatic exchange of financial account information (AEOI) with 8 additional countries. The AEOI with these partner states is scheduled to enter into force on January 1, 2027.
Supplementary tax: Date of application of the safe harbor rules on hybrid arbitrage arrangements in accordance with the administrative guidelines of December 18, 2023
The FTA announces that the rules regarding hybrid arbitrage arrangements under the temporary CbCR safe harbor of the administrative guidance of December 18, 2023 will apply to transactions after December 18, 2023.
Entry into force of the supplementary agreement (in particular home office) to the double taxation agreement between Switzerland and France
The supplementary agreement to the double taxation agreement between Switzerland and France entered into force on July 24, 2025.
Entry into force of the protocol of amendment to the double taxation agreement with Serbia
The protocol of amendment to the double taxation agreement (DTA) between Switzerland and Serbia entered into force on July 18, 2025. With a few exceptions, most of the amendments will apply from January 1, 2026.
Switzerland and Croatia sign protocol of amendment to double taxation agreement
On July 18, 2025, Switzerland and Croatia signed a protocol of amendment to the double taxation agreement (DTA) in the area of taxes on income and capital.
Supplementary tax: crediting of residual tax as the relevant tax for Swiss supplementary tax
On 24 July 2025, the FTA published a notice stating that the crediting of the residual tax as the relevant tax for Swiss supplementary tax is recognized as part of the minimum taxation of multinational groups of companies.
Special issues in trust and foundation structures
Workshop on "Special Issues in Trust and Foundation Structures" by Andrea Opel and Stefan Oesterhelt on the occasion of the ISIS seminar "Structuring Private Assets by Means of Trusts or Foundations" on October 31, 2023.
ISIS) seminar folder "Corporate Restructuring" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Corporate Restructuring" of August 29, 2023 under the direction of René Schreiber.
