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.
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.
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.
Entry into force of the Protocol of Amendment to the DTA with Japan
The Protocol of Amendment to the Double Taxation Agreement (DTA) between Switzerland and Japan has entered into force. With the exception of individual provisions, most of the amendments are applicable as of January 1, 2023.
Federal Council adopts dispatch on the amendment of the DTA with Tajikistan
On 16 November 2022, the Federal Council adopted the dispatch on the amending protocol to the DTA with Tajikistan. The protocol implements the minimum standards from the BEPS project.
Switzerland and United Arab Emirates sign protocol of amendment to DTA
Switzerland and the United Arab Emirates signed a protocol amending the agreement for the avoidance of double taxation (DTA) in the area of taxes on income in Abu Dhabi on November 5, 2022. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
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".
