Should Swiss financial institutions take part in the EU FASTER Directive?
The EU directive on Faster and Safer Tax Relief of Excess Withholding Taxes (FASTER) was formally approved at the end of 2024. The purpose of the directive is to make the refund procedure for withholding tax in the EU more efficient for investors and more secure for tax authorities. Member States will have to transpose the directive into national legislation by December 31, 2028, and these rules will become applicable from January 1, 2030. But what are the implications for Swiss-based financial institutions (FI)?
Need for practical adjustments in the case of intercantonal and international home office establishments
At the end of 2025, the OECD published an update to the OECD Model Tax Convention, which sets out in detail the conditions under which working from home can constitute a permanent establishment. The OECD introduces the new concept of a company's deemed power of disposal over its employees' homes. Based on the legal principles and previous Federal Supreme Court rulings, this article analyzes whether Swiss practice regarding home office permanent establishments should be adapted in light of this new concept and the experience gained from several years of home office work.
Tax issues relating to real estate - current trends and hot topics
This issue is entirely dedicated to the topic of "Real Estate". The four articles shed light on the key issues that shape practice today. Real estate forms its own universe in tax law: the issues are complex and cantonal in nature. Between current taxation, property gains, corporate law structures and international interdependence, it is clear that even supposedly classic issues raise new questions. The latest developments impressively demonstrate how dynamic real estate taxation has become.
The Swiss taxation of real estate transactions in an international context
The Swiss real estate market is an increasingly interesting investment target for foreign investors. This article provides an introduction to the key tax aspects in connection with real estate transactions with cross-border implications. In addition to a brief outline of current tax issues, the article deals in depth with investments in commercial real estate and the question of whether an operating company or a real estate company exists for basic tax purposes, as well as the tax treatment of a sale of shares in a Swiss real estate company under Swiss unilateral law and treaty law.
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.
Cross-border restructuring
Workshop on "Cross-border Restructuring" by Patrick Schmid and Thomas Hug on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 2023.
Current cases on intercantonal and international corporate tax law (2023)
Workshop on intercantonal and international corporate tax law by René Matteotti and Philipp Betschart on the occasion of the ISIS seminar "Corporate Tax Law 2023" on June 19/20, 2023.
Seminar folder ISIS)-Seminar "Real Estate Transactions - Tax Consequences National and Cross-Border
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Real Estate Transactions - Tax Consequences National and Cross-Border" from September 12 and 13, 2022 under the direction of Julia von Ah.
