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 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.
Mutual agreement between Switzerland and Liechtenstein
On 02 March 2022, SIF announced the termination of the Mutual Understanding between Switzerland and Liechtenstein of 20/22 October 2020 on the impact of COVID-19 measures on the treatment of cross-border commuters under the DTA on 31 March 2022.
Tax relief for Ireland and the Philippines
On 25 February 2022, SIF updated the overview of the effects of the agreement on tax relief for Ireland and the Philippines.
Update of the overview of the effects of the agreement (extent of relief) concerning Australia
The State Secretariat for International Financial Matters (SIF) has updated the overview of the effects of the agreement (extent of relief) concerning Australia.
OECD publishes Transfer Pricing Guidelines
On 20 January 2022, the OECD published the latest version 2022 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Federal Council opens consultation on the automatic exchange of information with twelve other partner states
At its meeting on 3 December 2021, the Federal Council opened the consultation on the introduction of the automatic exchange of information on financial accounts (AEOI) with twelve additional states and territories.
Memorandum of Understanding between Switzerland and France
On 7 December, SIF announced that the mutual agreement between Switzerland and France of 13 May 2020 on the taxation of cross-border workers who work in the home office as a result of measures to combat Covid-19 will remain in force until 31 March 2022. Unless terminated by either party, it will then remain in force until 30 June 2022.
Switzerland as a location for the tax planning of international corporations (inbound)
Workshop on the occasion of the ISIS) seminar of 8 March 2018 entitled "Structuring Cross-Border Business Activities
Tax challenges of cross-border business activities for Swiss groups
Workshop on the occasion of the ISIS) seminar of 8 March 2018 entitled "Structuring Cross-Border Business Activities
