Partnerships and other personal legal entities for supplementary taxes
It is not uncommon for privately held groups to have partnerships and other personal legal entities such as trusts, foundations or private individuals linked by shareholders' agreements at the top of the structure. This article analyzes how such legal entities are to be treated for Swiss and international supplementary taxes and to what extent the provisions of Swiss income and profit tax law have an influence on this.
Cross-border commuter regulation Switzerland-France
The home office has fundamentally changed cross-border taxation - also in the relationship between Switzerland and France. New rules have applied to French cross-border commuters since 2023, which allow more flexibility but also place greater demands on employers and employees. This article provides a concise overview of the current tax framework and shows what should be paid particular attention to.
Tax-exempt legal entities for profit and supplementary taxes in Switzerland - A legal comparison
Not only the federal, cantonal and communal taxes on profits (DBG, StHG), but also the supplementary taxes (GloBE model regulations, MindStV) recognize the concept of subjective tax exemption for legal entities. The regulations are basically congruent, but there are several case constellations of practical relevance in which the supplementary taxes override the profit tax exemption (e.g. cantonal banks, health insurance companies, newly established companies). The author therefore sees a need for action on the part of legislators and tax authorities.
Taxation of spouses in international relationships - Federal Supreme Court ruling of September 23, 2024 Prejudice on tax separation issues
In its ruling of September 23, 2024, the Federal Supreme Court issued a long-awaited precedent on the issue of international tax differentiation of debts and debt interest in the case of international spouses and revised its ruling of March 2023 on the international transfer of maintenance payments to the divorced spouse. What does this precedent mean for practice and how should other exciting practical cases be handled?
Federal Council adopts dispatch on AEOI with 12 other partner states
At its meeting on 18 May 2022, the Federal Council adopted the dispatch on the introduction of AEOI with 12 other partner states.
Federal Council adopts dispatch on the amendment of the double taxation agreement with Armenia
The Federal Council adopted the dispatch on the Protocol of Amendment to the DTA on 4 May 2022.
Memorandum of Understanding between Switzerland and France
On 12 April 2022, SIF notified the conclusion of a mutual agreement dated 11 April 2022 to repeal the mutual agreement on the effects of measures to combat Covid-19 under the Switzerland-Germany DTA.
Working visit by Federal Councillor Ueli Maurer to his German counterpart
Federal Councillor Ueli Maurer met the German Finance Minister Christian Lindner for a working visit on 28 March 2022. The exchange concerned, among other things, the OECD/G20 project on taxing the digital economy.
Federal Council adopts dispatch on DTA with Ethiopia
On 18 March 2022, the Federal Council adopted the dispatch on the DTA with Ethiopia. With this DTA, Switzerland is extending its network of agreements to East Africa for the first time.
Federal Council opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Taxation of pension benefits in international circumstances
Case studies and formulated solutions from the workshop by Andrea Opel and Andrea Hildebrand. This workshop was part of the ISIS seminar on September 22/23, 2025 entitled "Pensions and Insurance".
Transfer pricing documentation - International and Switzerland (2025)
Workshop by Ivo Manatschal, Simona Studer and Thomas Hug on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Transfer pricing documentation - International and Switzerland"
