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.
One Uber as a digital business location?
Based on the concrete example of Uber , the aim of this paper is to find answers to the following questions: Can users play a decisive role in the value creation of a company in the digital economy? And if so, how can they be used to address the challenges of taxation in the digital economy?
Entry into force of the Protocol of Amendment to the DTA with Armenia
According to SIF's notification, the Protocol of Amendment to the DTA with Armenia entered into force on May 2, 2023. Most of the amendments are applicable as of January 1, 2024.
Federal Council adopts dispatch on the amendment of the double taxation agreement with the United Arab Emirates
On May 4, 2022, the Federal Council adopted the Dispatch on the Protocol of Amendment to the DTA with UAE.
Switzerland and Italy sign declaration to remove Switzerland from Italian blacklist
Federal Councillor Karin Keller-Sutter and Italian Finance Minister Giancarlo Giorgetti signed a political declaration on 20 April 2023 to settle outstanding tax issues.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
FTA publishes circular "Instruction sheets and DTA overviews for withholding tax".
With the circular Leaflets for Withholding Tax and Overviews of Double Taxation Treaties dated January 27, 2023, the FTA informs about changes in the double taxation treaties (DTAs), the various withholding tax leaflets and the related DTA overviews as of January 1, 2023.
Consultation agreement between Switzerland and Germany concerning withholding taxes
The State Secretariat for International Financial Matters SIF announces that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the procedure for relief from German withholding taxes on dividends, interest and royalties under the double taxation agreement between Switzerland and Germany.
Memorandum of Understanding between Switzerland and France on cross-border home office
According to media releases from the Federal Tax Administration (FTA) and the Federal Department of Finance (FDF) dated December 22, 2022, Switzerland and France have agreed on a solution for the taxation of home office income, which will apply from January 1, 2023. According to this, up to 40 percent of the working time per year can be performed in the home office without this having any impact on the state of taxation of income from employment - especially for cross-border commuters.
Home office - No extension of the mutual agreement between Switzerland and Italy
On December 22, 2022, the State Secretariat for International Financial Matters (SIF) announced that the mutual agreement between Switzerland and Italy of June 18-19, 2020, which includes, among other things, exceptional and temporary special rules for home office taxation, will remain in force only until January 31, 2023.
Tax challenges of cross-border business activities for Swiss groups
Workshop on the occasion of the ISIS) seminar of 8 March 2018 entitled "Structuring Cross-Border Business Activities
