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?
Cross-border commuter agreement with Italy has entered into force
On July 19, 2023, SIF announced that the new cross-border commuter agreement with Italy and an amending protocol to the DTA entered into force on July 17, 2023. The provisions are applicable as of January 1, 2024.
Memorandum of Understanding between Switzerland and France
On July 6, 2023, SIF announced that Switzerland and France have agreed on a common interpretation of the 10-day rule for business trips that qualify as home offices under the December 22, 2022 Memorandum of Understanding.
Switzerland and France sign an additional agreement to the bilateral double taxation agreement
On June 27, 2023, an additional agreement to the bilateral DTA was signed in Paris, which contains new and permanent taxation rules for home office income.
Switzerland and Slovenia sign Protocol of Amendment to DTA
On May 30, 2023, Switzerland and Slovenia signed an amendment protocol to the DTA. The protocol contains an abuse provision in the form of a PPT clause.
Entry into force of the Protocol of Amendment to the DTA with Armenia
According to SIF's notification, the Protocol of Amendment to the DTA with Armenia entered into force on May 2, 2023. Most of the amendments are applicable as of January 1, 2024.
Federal Council adopts dispatch on the amendment of the double taxation agreement with the United Arab Emirates
On May 4, 2022, the Federal Council adopted the Dispatch on the Protocol of Amendment to the DTA with UAE.
Switzerland and Italy sign declaration to remove Switzerland from Italian blacklist
Federal Councillor Karin Keller-Sutter and Italian Finance Minister Giancarlo Giorgetti signed a political declaration on 20 April 2023 to settle outstanding tax issues.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
ISIS seminar folder "Gratuitous transfer of assets under tax law"
All documents from the ISIS) seminar "Gratuitous transfer of assets in tax law" from October 28, 2025 under the direction of Peter Mäusli-Allenspach in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
Practical examples of cross-border issues in relation to Germany
Case studies, slides and detailed solution notes from the workshop held by Hanna Brozzo and Iring Christopeit on October 28, 2025 on the occasion of the ISIS seminar "Gratuitous asset transfers in tax law".
