Declaration obligations, advisor liability and mitigation of penalties: hot topics in criminal tax law
If declaration obligations are breached - both in the mixed assessment procedure and in the self-assessment system - which lead to a (possible) tax reduction, the question of criminal liability regularly arises in addition to the levying of any additional tax. The representative of the taxable person is increasingly being targeted by the tax authorities.
Criminal tax law risks of tax advice
As the legally compliant fulfillment of tax obligations requires knowledge of tax law, which the taxpayer often lacks in whole or in part, many taxpayers seek help in fulfilling their declaration obligations. If there are declaration errors that lead to at least the threat of a tax loss, the involvement of a specialist does not release the taxpayer from their responsibility for their tax declaration. Conversely, the professional involved, the tax advisor, can also be targeted by the authorities responsible for prosecuting tax offenses.
Dangerous game with risk of discovery - The criminal tax liability of external advisors and internal functionaries in the light of the Federal Supreme Court rulings 6B_90/2024 and 6B_93/2024
The Federal Supreme Court rulings 6B_90/2024 and 6B_93/2024 of February 3, 2025 raise fundamental questions regarding the criminal liability of tax advisors. The focus is on the requirements for perpetration of tax evasion and incitement to do so, as well as the distinction between permissible tax advice and punishable cooperation. The judgments shed light on the different roles of internal and external advisors and their significance for practice and the application of the law.
Unfair conduct by taxpayers when determining tax domicile in an intercantonal relationship
As tax evasion presupposes a breach of procedural obligations, this article takes a closer look at the procedural obligations, in particular the taxpayer's duty to cooperate, both in ordinary assessment proceedings and in tax domicile proceedings. Finally, the supplementary tax procedure is also addressed, taking into account the latest case law of the Federal Supreme Court on the terms "unknown" or "new" facts and evidence.
FTA publishes withholding tax rates 2025
The Federal Tax Administration (FTA) has published the 2025 withholding tax rates for all cantons.
Federal Council adopts dispatch on the popular initiative "For a social climate policy - fairly financed through taxation (Initiative for a future)" (inheritance tax initiative)
On December 13, 2024, the Federal Council adopted the dispatch on the popular initiative "For a social climate policy - fairly financed through taxation (Initiative for a future)". It rejected the initiative of the Young Socialists (JUSO) without a direct counter-proposal or indirect counter-proposal.
Federal Council introduces retroactive purchase option for pillar 3a
From January 1, 2025, people working in Switzerland who have not paid the maximum permissible contributions into their pillar 3a every year since the bill came into force will be able to pay these contributions retroactively for up to ten years and deduct these purchases from their taxes.
FDF reduces tax-free limit for travel to CHF 150
At its meeting on October 16, 2024, the Federal Council was informed by the Federal Department of Finance (FDF) about the reduction in the value exemption limit for travel.
FTA publishes withholding tax rates 2025
The Federal Tax Administration (FTA) published the 2025 withholding tax rates on October 8, 2024.
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 compensate for the consequences of cold progression. The latest changes concern the 2025 tax year.
RS professional expense allowances and remuneration in kind 2025 published
The FTA has published the circular "Professional expense allowances and remuneration in kind 2025 / Compensation for the consequences of cold progression in direct federal tax for the 2025 tax year".
Federal Council rejects JUSO popular initiative
At its meeting on May 15, 2024, the Federal Council defined its position on the popular initiative "For a social climate policy - fairly financed through taxation". It is of the opinion that the initiative is not a suitable means of achieving Switzerland's climate targets. In particular, it reduces the attractiveness of Switzerland for wealthy individuals. The Federal Council intends to recommend that Parliament reject the initiative without a direct counter-proposal or indirect counter-proposal.
Private asset management versus commercial trading
Workshop by Patrick Waldburger and Toni Hess on the occasion of the ISIS) seminar on September 23-24, 2024 entitled "Private asset management versus commercial trading"
Investments in crypto assets
Workshop by Silvan Guler and Daniel Bürki on the occasion of the ISIS) seminar on September 23-24, 2024 entitled "Investments in crypto assets"
Current problems of taxation of stock corporations and shareholders (2024)
Workshop by Oliver Jäggi and Benno Eberhard on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current problems of taxation of stock corporations and shareholders"
ISIS) seminar folder "Startups - tax and duty law challenges: Refinancing and Exit" (2024)"
All documents from the ISIS) seminar "Startups - Tax and Duty Law Challenges: Refinancing and Exit" from May 27, 2024 under the direction of Ruth Bloch-Riemer 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.
