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 opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Mutual agreement between Switzerland and Liechtenstein
On 02 March 2022, SIF announced the termination of the Mutual Understanding between Switzerland and Liechtenstein of 20/22 October 2020 on the impact of COVID-19 measures on the treatment of cross-border commuters under the DTA on 31 March 2022.
Tax relief for Ireland and the Philippines
On 25 February 2022, SIF updated the overview of the effects of the agreement on tax relief for Ireland and the Philippines.
Update of the overview of the effects of the agreement (extent of relief) concerning Australia
The State Secretariat for International Financial Matters (SIF) has updated the overview of the effects of the agreement (extent of relief) concerning Australia.
OECD publishes Transfer Pricing Guidelines
On 20 January 2022, the OECD published the latest version 2022 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Federal Council opens consultation on the automatic exchange of information with twelve other partner states
At its meeting on 3 December 2021, the Federal Council opened the consultation on the introduction of the automatic exchange of information on financial accounts (AEOI) with twelve additional states and territories.
Memorandum of Understanding between Switzerland and France
On 7 December, SIF announced that the mutual agreement between Switzerland and France of 13 May 2020 on the taxation of cross-border workers who work in the home office as a result of measures to combat Covid-19 will remain in force until 31 March 2022. Unless terminated by either party, it will then remain in force until 30 June 2022.
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".
