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?
Federal Council adopts dispatch on the exchange of information on OECD minimum taxation
At its meeting on September 12, 2025, the Federal Council adopted the dispatch on the approval of the international legal basis for the exchange of information for OECD minimum taxation.
Federal Council opens consultation on AEOI with 8 other partner states
At its meeting on August 13, 2025, the Federal Council opened the consultation on the introduction of the automatic exchange of financial account information (AEOI) with 8 additional countries. The AEOI with these partner states is scheduled to enter into force on January 1, 2027.
Supplementary tax: Date of application of the safe harbor rules on hybrid arbitrage arrangements in accordance with the administrative guidelines of December 18, 2023
The FTA announces that the rules regarding hybrid arbitrage arrangements under the temporary CbCR safe harbor of the administrative guidance of December 18, 2023 will apply to transactions after December 18, 2023.
Entry into force of the supplementary agreement (in particular home office) to the double taxation agreement between Switzerland and France
The supplementary agreement to the double taxation agreement between Switzerland and France entered into force on July 24, 2025.
Entry into force of the protocol of amendment to the double taxation agreement with Serbia
The protocol of amendment to the double taxation agreement (DTA) between Switzerland and Serbia entered into force on July 18, 2025. With a few exceptions, most of the amendments will apply from January 1, 2026.
Switzerland and Croatia sign protocol of amendment to double taxation agreement
On July 18, 2025, Switzerland and Croatia signed a protocol of amendment to the double taxation agreement (DTA) in the area of taxes on income and capital.
Supplementary tax: crediting of residual tax as the relevant tax for Swiss supplementary tax
On 24 July 2025, the FTA published a notice stating that the crediting of the residual tax as the relevant tax for Swiss supplementary tax is recognized as part of the minimum taxation of multinational groups of companies.
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)"
