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?
Switzerland and Tajikistan sign Protocol of Amendment to Double Taxation Agreement
On July 11, 2022, SIF informed that on July 04, 2022, Switzerland and Tajikistan signed a protocol amending the Convention on the avoidance of double taxation in the field of taxes on income and capital.
The Confederation regulates the implementation of the OECD minimum tax in Switzerland
In order to implement the OECD/G20 project on the taxation of the digital economy, the Federal Council proposes a supplementary tax, with 25% of the revenue going to the Confederation and 75% to the cantons and municipalities.
VAT refund to foreign companies
The Federal Administrative Court has confirmed the practice of the FTA regarding the content of the entrepreneur's certificate: This must be valid for the remuneration period (calendar year).
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.
Special problems of international tax planning of private investments, including international administrative and legal assistance in tax matters
Workshop on the occasion of the ISIS) seminar on 10-11 September 2018 entitled "Current Problems of Taxation of Private Investments".
Current questions on withholding tax and stamp duties, including international issues (2018)
Workshop on the occasion of the ISIS) seminar on 4-5 June 2018 entitled "Current problems and perspectives of corporate tax law".
