The Liechtenstein "Blockchain Law" (TVTG) from the perspective of tax consulting
The article shows that although there is now a legal basis for the token economy in Liechtenstein, no adjustments to the tax law are necessary. This is because the economic approach to tax law means that a situation can be subsumed and assessed from a tax perspective regardless of the technology used.
The Liechtenstein private law establishment with divided or undivided capital
The Liechtenstein private law establishment is a very versatile and flexible legal form which is unknown under Swiss company law and cannot generally be assigned to corporations or foundations. The article deals with the "establishment" as a special feature of Liechtenstein company law.
Taxation of spouses in international relations
An "international" spouse relationship from a tax law perspective exists if only one spouse is subject to unlimited tax liability in Switzerland, while the other spouse has no or only limited tax liability in Switzerland. It must also be a legally and factually unseparated marriage. The taxation of such "international" spousal relationships is opposed by the addition of factors as prescribed by law. However, according to the established case law of the Federal Supreme Court, the latter - unlike in intercantonal relations - cannot create any tax liability in Switzerland.
Tax rulings - Swiss success model at risk?
Tax rulings are omnipresent in Swiss tax consulting. With the StAhiV, they have been incorporated into Swiss legislation for the first time as of 1 January 2017 and are referred to there as "preliminary tax assessments", about which other states must be informed in certain situations. Recently, the courts have also been increasingly concerned with questions relating to tax rulings.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Federal Council adopts dispatch on the new Federal Act on the International Automatic Exchange of Information on Salary Data
At its meeting on May 14, 2025, the Federal Council adopted the dispatch on the international automatic exchange of information on salary data.
Federal Council wants to amend the minimum taxation ordinance
At its meeting on April 30, 2025, the Federal Council opened the consultation on an amendment to the Minimum Tax Ordinance (MindStV). The Minimum Tax Ordinance is to be supplemented by the rules on the international reporting obligation (GloBE Information Return, GIR).
Tax relief for Norway
On April 24, 2025, the SIF published an overview of the effects of the agreement on tax relief for Norway.
Tax relief for various countries
On April 7, 2025, the SIF updated the overview of the effects of the agreement (extent of relief) for various countries.
Switzerland and Zimbabwe sign a double taxation agreement
On March 19, 2025, Switzerland and Zimbabwe signed an agreement on the avoidance of double taxation (DTA) in the area of income taxes in Harare.
Memorandum of Understanding between Switzerland and Italy - Administrative cooperation
On March 19, 2025, the SIF reported that the competent authorities of Switzerland and Italy, in accordance with Art. 7 para. 1 of the Agreement of December 23, 2020 between Switzerland and Italy on the taxation of cross-border commuters, have defined the details of the application of administrative cooperation by mutual agreement.
International transactions involving intellectual property
Workshop by Napoleão Dagnese, Balthasar Denger and Thomas Hug on the occasion of the ISIS) seminar on 27 June 2022 entitled "International transactions involving intellectual property".
Current cases on intercantonal and international corporate tax law
Workshop by René Matteotti and Philipp Betschart at the ISIS) seminar on 13/14 June 2022 entitled "Corporate Tax Law 2022".