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.
Development of case law on the interpretation of the DTA Germany - Switzerland in 2014
The following contribution presents the 2014 case law of the German and Swiss tax courts regarding the application and interpretation of the Convention between the Federal Republic of Germany and the Swiss Confederation for the Avoidance of Double Taxation in the Field of Taxes on Income and Capital of 11 August 1971 (hereinafter referred to as the DTA). This contribution is a continuation of the overviews published in previous years on the development of case law on the interpretation of the DBA Germany/Switzerland.
Home Office - Tax treatment in the cross-border area
Today, many tasks can be done from anywhere. The traditional workplace in the office has had its day. A telecommuting job at home brings advantages for both sides: The employer saves the costs of renting the room, the employee saves the way to the office. The following article examines the question of whether working from home can give rise to a tax permanent establishment in cross-border international situations. For the purposes of this paper, "home office" means a room or rooms which are located in the employee's home and which are used, at least in part, not only for residential purposes but also for work purposes.
Development of case law on the interpretation of the DTA Germany/Switzerland in 2013
The following contribution presents the case law of the German tax courts from 2013 with regard to the application and interpretation of the Convention between the Federal Republic of Germany and the Swiss Confederation for the Avoidance of Double Taxation in the Field of Taxes on Income and Capital of 11 August 1971 (hereinafter referred to as the DTA). This contribution is a continuation of the overviews published in previous years on the development of case law on the interpretation of the DBA Germany/Switzerland.
Federal Council adopts dispatch on double taxation agreement with Zimbabwe
At its meeting on November 5, 2025, the Federal Council adopted the dispatch on the DTA with Zimbabwe.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on October 16, 2025 that the competent authorities of Switzerland and Germany have agreed to extend the consultation agreement on the application of Article 15 paragraph 4 of the double taxation agreement between Switzerland and Germany.
Signing and opening of the consultation on the protocol of amendment to the AEOI Switzerland-EU in tax matters
The Protocol of Amendment to the Agreement on the Automatic Exchange of Financial Account Information to Promote Tax Compliance in International Matters, signed on October 20, 2025, adapts the agreement to the amended OECD standard and supplements it with new provisions on administrative assistance in the collection of VAT claims. The consultation will last until February 6, 2026.
Federal Council adopts dispatch on the exchange of information on OECD minimum taxation
At its meeting on September 12, 2025, the Federal Council adopted the dispatch on the approval of the international legal basis for the exchange of information for OECD minimum taxation.
Federal Council opens consultation on AEOI with 8 other partner states
At its meeting on August 13, 2025, the Federal Council opened the consultation on the introduction of the automatic exchange of financial account information (AEOI) with 8 additional countries. The AEOI with these partner states is scheduled to enter into force on January 1, 2027.
Supplementary tax: Date of application of the safe harbor rules on hybrid arbitrage arrangements in accordance with the administrative guidelines of December 18, 2023
The FTA announces that the rules regarding hybrid arbitrage arrangements under the temporary CbCR safe harbor of the administrative guidance of December 18, 2023 will apply to transactions after December 18, 2023.
Entry into force of the supplementary agreement (in particular home office) to the double taxation agreement between Switzerland and France
The supplementary agreement to the double taxation agreement between Switzerland and France entered into force on July 24, 2025.
Entry into force of the protocol of amendment to the double taxation agreement with Serbia
The protocol of amendment to the double taxation agreement (DTA) between Switzerland and Serbia entered into force on July 18, 2025. With a few exceptions, most of the amendments will apply from January 1, 2026.
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".
