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 Cyprus sign Protocol of Amendment to the Double Taxation Convention
On 20 July 2020, Switzerland and Cyprus 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 with regard to double taxation agreements.
Switzerland and Liechtenstein sign Protocol of Amendment to the Double Taxation Convention
On 14 July 2020, Switzerland and Liechtenstein 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.
Signing of a Memorandum of Understanding with the USA
The competent authorities of Switzerland and the USA signed a Memorandum of Understanding on 19 June in Bern and on 25 June in Washington.
Memorandum of Understanding between Switzerland and Italy concerning COVID-19 measures
On 20 June 2020, the State Secretariat for International Financial Matters (SIF) reported the conclusion of a new memorandum of understanding between Switzerland and Italy concerning COVID-19 measures.
Consultation agreement with Germany on the taxation of cross-border workers and state support services
On 11 June 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of cross-border commuters and the treatment of state support services.
Council of States approves various double taxation agreements
At its meeting on 4 June 2020, the Council of States approved various double taxation agreements (DTAs).
SIF updates tax relief tables for various countries (4 June 2020)
On 4 June 2020, the State Secretariat for International Financial Matters (SIF) updated the overviews of tax relief for various countries. This concerns the overviews of the effects (extent of the relief) of the agreements with Bangladesh, China, Chinese Taipei, India, Ireland, Malaysia, the Philippines, Singapore and Sri Lanka.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on August 30, 2022, entitled "Restitution in International Relations - Current Practice and Problem Areas".
International transactions involving intellectual property
Workshop by Napoleão Dagnese, Balthasar Denger and Thomas Hug on the occasion of the ISIS) seminar on 27 June 2022 entitled "International transactions involving intellectual property".
