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?
Tax relief for various countries
On April 7, 2025, the SIF updated the overview of the effects of the agreement (extent of relief) for various countries.
Switzerland and Zimbabwe sign a double taxation agreement
On March 19, 2025, Switzerland and Zimbabwe signed an agreement on the avoidance of double taxation (DTA) in the area of income taxes in Harare.
Memorandum of Understanding between Switzerland and Italy - Administrative cooperation
On March 19, 2025, the SIF reported that the competent authorities of Switzerland and Italy, in accordance with Art. 7 para. 1 of the Agreement of December 23, 2020 between Switzerland and Italy on the taxation of cross-border commuters, have defined the details of the application of administrative cooperation by mutual agreement.
Supplementary tax: Tax treatment of business units that qualify as permanent establishments
On March 18, 2025, the FTA explained the treatment of business units that are considered permanent establishments in a communication on the minimum taxation of multinational enterprise groups.
Federal Council opens consultation on change to FATCA model
At its meeting on March 7, 2025, the Federal Council opened the consultation process for a new FATCA agreement.
Federal Council opens consultation on the exchange of information on OECD minimum taxation
On January 29, 2025, the Federal Council opened the consultation on the exchange of information regarding OECD minimum taxation.
Remboursement de l'impôt anticipé: pratique des anciennes réserves, liquidation remplaçante et transposition internationale étendue
Cas pratiques présentés par Stefan Oesterhelt et Raphaël Fellay lors du séminaire ISIS) du 03 novembre 2021, intitulé "Restructurations / Fusions / Acquisitions".
Transfert de siège et restructurations transfrontalières
Cas pratiques présentés par Rebecca Dorasamy lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
