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.
Federal Council enacts new legal basis for the implementation of international agreements in the tax area
In the StADG, the provisions of the existing national federal law of 22 June 1951 on the implementation of federal intergovernmental agreements for the avoidance of double taxation and the ordinances based on it are taken over as far as necessary and supplemented with new provisions. It now regulates the essential points for the relief of withholding tax as well as penalty provisions in connection with the relief of withholding taxes on investment income. It also regulates how mutual agreement procedures are to be carried out domestically if the applicable agreement does not contain any provisions to the contrary.
FTA publishes final rulings on the FATCA agreement
On 22 October 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Chair of the OECD Forum on Tax Administration (FTA) and the Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) release statement on Pandora Papers
On 14 October 2021, the Chair of the OECD Forum on Tax Administration (FTA) and the Chair of its Joint International Task Force on Shared Intelligence and Collaboration (JITSIC) issued a joint statement on the Pandora Papers.
Federal Councillor Ueli Maurer at the meeting of the G20 finance ministers and the annual meeting of the IMF and World Bank
On 9 and 10 July 2021, Federal Councillor Ueli Maurer, together with SNB President Thomas Jordan, took part in the meeting of the G20 finance ministers and central bank governors.
Exchange of information with 96 countries on around 3.3 million financial accounts
According to the media release of the Federal Tax Administration (FTA) of 7 October 2019, the FTA has exchanged information on financial accounts with 96 countries. The exchange takes place within the framework of the global standard on the automatic exchange of information (AEOI).
FTA publishes FATCA final rulings (III; supplement)
On 30 September 2021, the Federal Tax Administration (FTA) notified the issuance of final rulings pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Media release on Switzerland's position in connection with the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
On 8 October 2021, the Inclusive Framework of the OECD (including Switzerland) specified the key parameters for the future taxation of large, internationally active companies (see our article of 9 October 2021). According to a media release, Switzerland demands that the interests of small, economically strong countries be taken into account in their implementation and that legal certainty be created for the companies affected.
OECD publishes key points on the future taxation of the digitalised economy (Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy)
On 8 October 2021, the OECD published the "Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy". The document specifies the cornerstones for the future taxation of the digitalised economy on the basis of two pillars.
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".
