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.
SIF publishes agreement on DTA between Switzerland and Colombia
On 5 March 2019, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MoU) on the Agreement between the Swiss Confederation and the Republic of Colombia on the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 26 October 2007 (DTA Switzerland-Colombia).
Double Taxation Convention
The Commission also follows the decision of the National Council from the last winter session and requests approval of the double taxation agreement with Brazil (18,064; 10 votes to 1 with 1 abstention) and the United Kingdom (18,062; unanimously).
Withholding tax according to DBA
The Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) has updated the overviews of the contractual limits on foreign taxes, the tax relief for Swiss dividends and interest, and the countries whose agreements contain abuse provisions.
The Tax Information Agreement with Brazil has entered into force
The Tax Information Agreement between Switzerland and Brazil entered into force on 4 January 2019. The provisions of the Agreement shall be applied from 1 January 2020.
Federal Council repeals the transitional provision in the Ordinance on the International Automatic Exchange of Information in Tax Matters
At its meeting on 7 November 2018, the Federal Council decided to repeal the transitional provision on the term "participating states" in the Ordinance on the International Automatic Exchange of Information in Tax Matters as of 1 January 2019. This will implement an international requirement.
Commission suspends consultation on double taxation agreement with Saudi Arabia
Following the murder of the journalist Khashoggi, the Commission has decided to suspend discussion of this agreement until the Federal Council has thoroughly reviewed Switzerland's relations with Saudi Arabia.
First exchange of information on around 2 million financial accounts
The Federal Tax Administration (FTA) has exchanged information on financial accounts for the first time. The exchange takes place within the framework of the global standard for automatic information exchange (AIA).
Federal Council adopts dispatch on double taxation agreement with Brazil
On 5 September 2018 the Federal Council adopted the dispatch on the double taxation agreement (DTA) in the area of income taxes with Brazil. This is the first DTA between Switzerland and Brazil. The agreement was signed in Brasilia on 3 May 2018 and will come into force following approval by the parliaments of both countries.
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".
