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?
Regulation on international administrative assistance (9 May 2018)
At its meeting on 9 May 2018, the Federal Council adopted the dispatch on the approval of the agreements on the automatic exchange of information on financial accounts (AIA) with Singapore and Hong Kong. With the same dispatch, the Federal Council is proposing to parliament the introduction of the AIA with other financial centres. In October 2017, the Federal Council decided to apply the agreements with Singapore and Hong Kong provisionally as of 1 January 2018 and to exchange account information with these countries for the first time in autumn 2019. This was the only way to ensure that the timetable could be adhered to. With the current proposal, the Federal Council is now asking the Federal Assembly for authorisation to ratify the two agreements. At the same time, the Federal Council is proposing as an option to implement the AIA with Singapore and Hong Kong based on the Multilateral Competent Authority Agreement (MCAA) on the automatic exchange of information on financial accounts. This solution takes into account the latest developments in Singapore and Hong Kong and would allow the AIA to be implemented on a multilateral basis.
Social security law
Workshop by Franziska Stadtherr and Andreas Schiek on the occasion of the ISIS) seminar on May 22, 2025 entitled "Social Security Law"
Appeal proceedings taking into account intercantonal and international aspects (2 parts)
Workshop by Ruth Bloch-Riemer and Toni Hess on the occasion of the ISIS) seminar on May 5, 2025 entitled "Appeal procedures taking into account intercantonal and international aspects (2 parts)"
