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?
Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
International supplementary tax IIR to come into force in 2025
At its meeting on September 4, 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force on January 1, 2025. In addition to the QDMTT, which was already introduced on January 1, 2024, this rule is intended to ensure that tax revenue remains in Switzerland.
Federal Council opens consultation on determining the partner states for the AEOI on crypto assets
At its meeting on August 14, 2024, the Federal Council opened the consultation on determining the partner states for the automatic exchange of information on crypto assets (AEOI on crypto assets). With this proposal, the Federal Council wants to determine when Switzerland should automatically exchange information on crypto assets with which partner states.
Switzerland and Hungary sign protocol of amendment to double taxation agreement
On July 12, 2024, Switzerland and Hungary signed a protocol of amendment to the DTA.
Switzerland and the USA agree on mutual exchange of information on financial data
Switzerland and the USA signed a new FATCA agreement in Bern on June 27, 2024. Switzerland currently provides information on financial accounts to the USA unilaterally. In future, it will also receive corresponding information from the USA as part of an automatic exchange of information. The model change is expected to apply from 2027.
Federal Council adopts dispatch on DTA with Angola
The Federal Council adopted the dispatch on the DTA with Angola on June 14, 2024.
Federal Council adopts dispatch on amending the DTA with Germany
On June 14, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Germany.
Federal Council opens consultation on the new Federal Act on the International Automatic Exchange of Information on Salary Data
The Federal Council opened the consultation procedure at its meeting on June 7, 2024. It is proposing a new law that regulates the automatic exchange of information on salary data in tax matters between Switzerland and a partner state with which an international treaty exists.
Switzerland and Italy sign permanent tax rules for working from home
On June 6, 2024, Switzerland and Italy signed a protocol of amendment to the existing cross-border commuters agreement, which permanently regulates the issue of taxation of home offices. The protocol of amendment will enter into force as soon as the corresponding approval processes in both countries have been completed and will apply retroactively from January 1, 2024.
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
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"
