Good news: Art. 23 VStG in conjunction Art. 70d VStG also applies to requests for reverse power under Art. 58 VStG
Since 1 January 2019, Art. 23 VStG in conjunction Art. 70d VStG concerning the non-forfeiture of the refund of withholding tax in force. The new regulation applies to claims that have not yet been legally decided since 1 January 2014 and, according to a new Federal Supreme Court decision, also applies to cases in which a tax office offset income and refunded the withholding tax, but reclaimed it after a reduction order by the EStV and the taxpayer appealed against it.
Refund of withholding tax under the new Art. 23(2) VStG - an interpretative regulation
The reimbursement of withholding tax to domestic recipients of services requires, among other things, that the income subject to withholding tax and the assets on which it is based are declared "in an orderly manner".
payments to employees of third parties - taxable income from employment
A commentary on the decision of the Federal Supreme Court of 15 March 2019 2C_703/2017.
Investing in art - Does Pablo Picasso still give pleasure after the tax bill? The fake, the stolen and the real Picasso in the light of civil and tax law
"Does Pablo Picasso still give pleasure after the tax bill?" The answer to the initial question depends on whether you bought a fake, a stolen or a genuine Picasso. We must therefore examine the initial question in the first step in the light of civil law and in the second step in the light of tax law. A Zurich art collector will accompany us on this journey. So much up front: when buying a real Picasso, there is still joy after the tax bill. The joy of a real Picasso is greater than the annoyance of the annual wealth tax bill sent by the tax authorities! We can understand the joy of a real Picasso a little better if we take a look back at the Basel Picasso year 1967.
FDF adjusts tax rates and deductions to inflation
The Federal Department of Finance (FDF) adjusts the rates and deductions for direct federal tax annually to offset the effects of cold progression. The latest changes concern the 2026 tax year.
FTA publishes new refund and default interest rates for federal taxes from 2026
On September 11, 2025, the Federal Tax Administration (FTA) published the new refund and default interest rates for federal taxes from 2026.
Federal Council and Parliament recommend reform of residential property taxation for approval
The Federal Council and Parliament recommend that the creation of a constitutional basis for cantonal property taxes on second homes be adopted on September 28, 2025. The bill is the prerequisite for a comprehensive reform of residential property taxation in Switzerland, which also aims to abolish the imputed rental value.
Federal Council adopts dispatch approving the list of 74 partner states for the automatic exchange of information on crypto assets
On June 6, 2025, the Federal Council adopted the dispatch approving the introduction of the international automatic exchange of information (AEOI) on crypto assets with the relevant partner states. Entry into force is planned for 2026 with the first exchange of data in 2027.
Clarification of Notice-024-DVS-2025-d of 22.04.2025 - Income and withholding tax: Determination of the maximum permissible conversion discount
On May 19, 2025, the FTA specified the future practice in Communication 024-DVS-2025 regarding the determination of the maximum permissible conversion discount.
Mutual agreement between Switzerland and Liechtenstein - Dormant estates
On May 19, 2025, the SIF announced that the competent authorities of Switzerland and Liechtenstein had concluded a mutual agreement pursuant to Art. 25 para. 3 DTA CH-FL to avoid double taxation of income and assets belonging to dormant estates under Liechtenstein law.
Questions choisies d'impôts directs, droits de donation et succession
Workshop by Nicolas Candaux and Arnaud Cywie on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
Discretionary assessment
Workshop by Jasmin Malla and Pascal Amsler on the occasion of the ISIS) seminar on 12 May 2022 entitled "Tax procedural law including appeal procedures".
