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.
OECD public consultation on Pillar One and Pillar Two in the taxation of digital business models
On 12th October the OECD published the blueprints for Pillar One and Pillar Two and launched a public consultation until 14th December 2020. The aim is to reach an agreement between the states on the open points by mid 2021.
FTA publishes understanding agreement on the DTA with Liechtenstein
On 12 October 2020, the State Secretariat for International Financial Matters (SIF) published a memorandum of understanding on the DTA with Liechtenstein concerning the treatment of income of FC Vaduz players resident in Switzerland under the DTA between Switzerland and Liechtenstein.
FTA - Memorandum of Understanding between Switzerland and Australia
On 15 September 2020 the Memorandum of Understanding on the procedural rules of the arbitration procedure provided for in Article 24 (Mutual agreement procedure) paragraph 5 of the Double Taxation Convention Switzerland - Australia was signed.
Memorandum of Understanding between Switzerland and France on the taxation of cross-border commuters for teleworking or home office work remains in force until the end of 2020
The State Secretariat for International Financial Matters (SIF) reported on 28 August 2020 that the provisional understanding agreement of 13 May 2020 between Switzerland and France on the taxation of frontier workers working in the home office as a result of measures to combat COVID-19 remains in force until 31 December 2020.
Federal Council adopts messages on the new DTA with Bahrain and on the amendments to the DTA with Kuwait
At its meeting on 26 August 2020, the Federal Council adopted the messages on a new double taxation agreement (DTA) with Bahrain and on the Protocol of Amendment to the DTA with Kuwait.
FTA publishes Circular Letter No. 49 "Proof of business-related expenses for foreign transactions abroad" and Circular Letter No. 50 "Inadmissibility of tax deduction of bribes paid to public officials".
On 13 July 2020, the FTA published Circular No. 49 "Evidence of business-related expenses for foreign-foreign transactions" and Circular No. 50 "Inadmissibility of the tax deduction of bribes paid to public officials". At the same time, the predecessor circulars of the same name, No. 9 of 22 June 2005 and No. 16 of 13 July 2007, are repealed.
Memorandum of Understanding between Switzerland and the USA
The State Secretariat for International Financial Matters (SIF) reports the conclusion of a memorandum of understanding between the Swiss Confederation and the United States of America concerning the rules of procedure of the arbitration procedure provided for in Art. 25 para. 6 and 7 DBA CH/USA.
Switzerland and Malta sign Protocol of Amendment to the Double Taxation Convention
On 16 July 2020, Switzerland and Malta signed a protocol amending the agreement to avoid double taxation (DTA) in the area of taxes on income and wealth. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
Current cases on intercantonal and international corporate tax law (2025)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 02 + 03, 2025 entitled "Current cases on intercantonal and international corporate tax law"
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
