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?
FTA publishes notices on FATCA group requests
On 30 November 2021, the Federal Tax Administration (FTA) published FATCA group requests pursuant to Article 12 paragraph 1 of the FATCA Act.
Consultation agreement between Switzerland and Germany
On 30 November 2021, SIF announced that the consultation agreement between Switzerland and Germany of 11 June 2020 concerning the taxation of cross-border workers during the COVID-19 pandemic will not be terminated until at least 31 March 2022.
Federal Council adopts dispatches on amendments to the DTAs with Japan and Northern Macedonia
The Dispatches on the Protocols of Amendment to the DTAs with Japan and Northern Macedonia were adopted by the Federal Council on 17 November 2021.
Switzerland and Armenia sign Protocol of Amendment to the Double Taxation Agreement
Switzerland and Armenia signed a Protocol of Amendment to the corresponding DTA on 12 November 2021. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements as well as the international standard in matters of information exchange.
FTA publishes final ruling on the FATCA agreement
On 19 November 2021, the Federal Tax Administration (FTA) notified the issuance of a final ruling pursuant to Art. 5 No. 3 lit. b FATCA Agreement.
Federal Councillor Ueli Maurer meets Russian Finance Minister Anton Siluanov
Federal Councillor Ueli Maurer met the Russian Finance Minister Anton Siluanov in Bern on 19 November 2021. One of the topics discussed was the revision of the existing double taxation agreement demanded by Russia.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Current cases on intercantonal and international corporate tax law (2024)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current cases on intercantonal and international corporate tax law"
Special issues in trust and foundation structures
Workshop on "Special Issues in Trust and Foundation Structures" by Andrea Opel and Stefan Oesterhelt on the occasion of the ISIS seminar "Structuring Private Assets by Means of Trusts or Foundations" on October 31, 2023.
ISIS) seminar folder "Corporate Restructuring" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Corporate Restructuring" of August 29, 2023 under the direction of René Schreiber.
