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.
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".
