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.
OECD publishes consultation document on the introduction of a global minimum tax on profits
As part of its project on taxation of the digital economy, the Organisation for Economic Cooperation and Development (OECD) published the consultation document on the introduction of a global minimum tax on profits (so-called "Global anti-Base Erosion" or "GloBE") on 8 November 2019.
Federal Council adopts dispatches on the amendments to the DTAs with New Zealand, the Netherlands, Norway and Sweden
At its meeting on 6 November 2019, the Federal Council adopted the dispatches concerning the amendment protocols to the double taxation agreements (DTAs) with New Zealand, the Netherlands, Norway and Sweden.
Federal Council adopts dispatch on the amendments to the DTA with Iran
At its meeting on 23 October 2019, the Federal Council adopted the dispatch on the Protocol of Amendment to the Agreement on the avoidance of double taxation in the area of taxes on income and wealth (DTA) with Iran.
OECD publishes proposal on taxation of multinational companies
On 9 October 2019, the Organisation for Economic Cooperation and Development (OECD) published a proposal to ensure that large and highly profitable multinational companies, especially IT companies, pay taxes.
EU removes Switzerland from its watch list
Switzerland meets international tax standards and implements them. The European Union is now acknowledging this and removing Switzerland from its watch list. The amendment shall enter into force upon publication of the revised Annexes in the Official Journal of the EU.
Federal Council adopts dispatch on the Protocol of Amendment to the DTA with Ukraine
At its meeting on 9 October 2019, the Federal Council approved the dispatch on the approval of a Protocol of Amendment to the Agreement to Avoid Double Taxation in the Area of Taxes on Income and Capital (DTA) between Switzerland and Ukraine. The protocol implements the minimum standards in double taxation agreements and also adapts the DTA to the current treaty policy of the two states.
Exchange of information with 75 countries on around 3.1 million financial accounts
According to the media release of the Federal Tax Administration (FTA) of 7 October 2019, the FTA has exchanged information on financial accounts with 75 countries. The exchange takes place within the framework of the global standard for automatic information exchange (AIA).
Protocol of Amendment to the DTA between Switzerland and the United States of America comes into force
Switzerland and the United States of America exchanged the instruments of ratification of the Protocol of Amendment to their Double Taxation Convention in the area of taxes on income (DTA) in Bern on 20 September 2019. The Protocol, which came into force on the same day, represents a milestone in tax relations between Switzerland and the USA.
Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Demarcation issues regarding social security subordination in an international context
Workshop by Jennifer Herren and Lukas Stotzer on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
