Tax issues relating to real estate - current trends and hot topics
This issue is entirely dedicated to the topic of "Real Estate". The four articles shed light on the key issues that shape practice today. Real estate forms its own universe in tax law: the issues are complex and cantonal in nature. Between current taxation, property gains, corporate law structures and international interdependence, it is clear that even supposedly classic issues raise new questions. The latest developments impressively demonstrate how dynamic real estate taxation has become.
The Swiss taxation of real estate transactions in an international context
The Swiss real estate market is an increasingly interesting investment target for foreign investors. This article provides an introduction to the key tax aspects in connection with real estate transactions with cross-border implications. In addition to a brief outline of current tax issues, the article deals in depth with investments in commercial real estate and the question of whether an operating company or a real estate company exists for basic tax purposes, as well as the tax treatment of a sale of shares in a Swiss real estate company under Swiss unilateral law and treaty law.
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.
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.
Current cases on intercantonal and international corporate tax law (2025)
Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 02 + 03, 2025 entitled "Current cases on intercantonal and international corporate tax law"
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
