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?
When does the tax authority treat easements as transactions that are equivalent to a sale of real estate?
The article analyzes the tax treatment of compensation paid in connection with the encumbrance by easements or their deletion. The focus is on the question of whether such transactions are equivalent to a sale and are subject to property gains tax. Legal criteria and practical examples are used to show how these cases are assessed under tax law.
Invalidity of discretionary assessments
With its latest decision of August 19, 2024 (9C_673/2023), published on September 25, 2024, the Federal Supreme Court confirms and clarifies its practice on the nullity of discretionary assessments.
Inheritance and gift tax at federal level - the so-called "Future Initiative" of the JUSO
The "Future Initiative" aims to tax the assets of natural persons through an additional inheritance and gift tax at federal level. With an exemption amount of CHF 50 million, the tax affects wealthy individuals. The proposed tax rate was set at 50%, without providing for exceptions to taxation. Due to the existing inheritance and gift taxes, this could lead to a much higher effective tax burden. Numerous unresolved questions and a planned retroactive effect are already causing great uncertainty well before a referendum at the beginning of 2026. This article uses examples to illustrate possible consequences and measures for action.
Memorandum of Understanding between Switzerland and Italy concerning COVID-19 measures
On 20 June 2020, the State Secretariat for International Financial Matters (SIF) reported the conclusion of a new memorandum of understanding between Switzerland and Italy concerning COVID-19 measures.
Consultation agreement with Germany on the taxation of cross-border workers and state support services
On 11 June 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of cross-border commuters and the treatment of state support services.
National Council adopts motion "Enabling purchases under Pillar 3a
In its session of 2 June 2020, the National Council adopted the motion "Enabling Pillar 3a purchases".
FDK rejects popular initiative "Relieve wages, tax capital fairly
On 2 June 2020, the Conference of Cantonal Finance Directors (FDK) published a press release on the popular initiative "Relieve the burden on wages, tax capital fairly".
Consultation agreement with Germany on the taxation of railway staff
On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
ESTV - Taxation of compensation for loss of earnings due to corona
On 6 April 2020, the Swiss Federal Tax Administration published the Circular on the tax treatment of benefits under the Ordinance on Measures for Loss of Earnings in Connection with the Coronavirus.
Fringe benefits / private shares / expenses / hidden profit distributions
Workshop by Franziska Spreiter and Christian Vassalli at the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
Differentiation between salary and dividend for employee shareholders
Workshop by Natalie Dini and Barbara Stötzer at the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
