Taxation of NFTs in the luxury industry - a case study
Non-fungible tokens ("NFTs" for short), i.e. unique cryptographic tokens representing physical or digital value, are currently on everyone's lips - at least since the NFT "Everydays: the First 5000 Days" was auctioned by Christie's in 2021 for USD 69.3 million. Using the NFTs of the watch brand DuBois et fils, which were issued for the first time in 2021, it will be shown how companies in the luxury sector can use NFTs both to market products and to build a close customer relationship, and which tax issues have to be taken into account.
Quasi-property trading - from the elasticity of the criteria
In its ruling, which was heard in public on October 13, 2022 and served on the parties in writing on March 30, 2023, the Federal Supreme Court dismissed the appeal of a married couple residing in the Canton of Zurich. It upheld the ruling of the Administrative Court of the Canton of Zurich, according to which the taxpayers had qualified as quasi-real estate dealers by selling a rented apartment building. The Federal Supreme Court based its decision on the fact that the taxpayers, who also held other rented properties in co-ownership, had taken a high financial risk when acquiring the property, had sold the property after a short holding period (5 ½ years), had spent a great deal of time managing the property during the holding period and had acquired it with the plan of achieving the highest possible profit upon sale. In their discussion of the ruling, the authors deal with the Federal Supreme Court's reasoning and explain why the ruling leads to legal uncertainties in practice.
Income tax-free repayment of a hidden capital contribution to the shareholder
The Federal Supreme Court had to decide for the first time whether the repayment of a hidden capital contribution to the shareholder constitutes taxable investment income or whether it can be made tax-free. After interpreting the term "repayment of contributions" in Art. 20 para. 3 DBG, it comes to the conclusion that hidden capital contributions also fall under this, that the accounting requirement from Art. 5 para. 1bis VStG is not relevant and that the repayment of a hidden capital contribution is income tax-free.
Algorithmically verified tax return in the ordinary mixed assessment procedure
The digitization of the tax area and, in particular, the automation of the assessment process are advancing. In the process, risk management systems can be used to automatically check the plausibility of tax returns. Such a risk analysis can lead to challenges under fundamental rights and data protection law, which must be countered in particular by creating specific legal foundations.
Tax-approved interest rates 2021 for advances or loans in Swiss francs and foreign currencies
The granting of interest-free or insufficiently interest-bearing advances or loans to participants or third parties related to them constitutes a payment in kind. This shall also apply to translated interest which is paid on the basis of obligations to participants or third parties close to them.
FTA publishes withholding tax rates 2021
The Federal Tax Administration (FTA) published the first withholding tax rates for 2021 (including corrections) on 4 and 10 December 2020.
Adjustment SSK-KS 28: New calculation of the capitalization rate and clarification regarding start-up companies
The Swiss Tax Conference published an updated version of SSK-KS 28 on 3 November, which concerns the calculation of the capitalisation rate for determining the capitalised earnings value and a clarification of the practice for the valuation of start-up companies.
FTA publishes circular "Information sheet on withholding tax on substitute income
On 29 October 2020, the Federal Tax Administration published the circular "Instruction sheet on the withholding tax on substitute income" (2-186-D-2020-e). This leaflet has been completely revised in the course of the provisions on the revision of withholding tax that will come into force on 1 January 2021.
FTA publishes update to circular no. 37 "Taxation of employee shareholdings
On 30 October 2020, the FTA published an update to Circular Letter No. 37 "Taxation of Employee Participation".
FTA publishes circular "Interest rates in the area of direct federal tax for the 2021 calendar year / maximum pillar 3a deductions in the 2021 tax year".
On 22 October 2020, the Federal Tax Administration (FTA) published the circular "Interest rates in the area of direct federal tax for the calendar year 2021 / maximum pillar 3a deductions in the 2021 tax year".
Canton of Zurich: Amendment of the directive on the valuation of usufruct and periodic benefits for inheritance and gift tax purposes
The directive of the Finance Directorate of the Canton of Zurich on the valuation of usufruct and claims to periodic benefits for inheritance and gift tax purposes has been updated due to changes in life expectancy.
Deduction of professional expenses in the light of COVID-19 in the tax return 2020 (Canton of Zurich)
On September 9, 2020, the Cantonal Tax Office of Zurich published a notice according to which dependent employees can deduct their professional expenses (e.g. travel expenses between home and place of work and meals) in their 2020 tax return as they would have been incurred without COVID-19.
ISIS) seminar folder "The world of work on the move: tax and social security challenges (2025)"
All documents from the ISIS) seminar "The world of work on the move: tax and social security challenges" held on May 22, 2025 under the direction of Petra Caminada in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents from the individual workshops according to the following content description.
Withholding taxes
Workshop by Dominique Frison and Jennifer Herren on the occasion of the ISIS) seminar on May 22, 2025 entitled "Withholding taxes"
