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.
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.
No extension of mutual assistance for fiscal offences
Following its decision not to revise the law on fiscal offences, the Federal Council has also decided not to extend mutual assistance in fiscal offences. In particular, it would put the Swiss tax authorities at a disadvantage compared to foreign tax authorities. The Federal Council took this decision at its meeting on 29 August 2018.
Intercantonal and cross-border real estate transactions
Workshop by Laetitia Fracheboud and Olivier Margraf on the occasion of the ISIS) seminar of 12/13 September 2022 entitled "Intercantonal and cross-border land transactions".
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on August 30, 2022, entitled "Restitution in International Relations - Current Practice and Problem Areas".
