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.
Intercantonal change of residence of persons subject to withholding tax, which are subsequently assessed in an orderly manner
In the case of an intercantonal change of residence of persons subject to withholding tax who are subsequently assessed in an orderly manner, the question arises as to which canton or cantons have the right to tax the earned income and other income and taxable assets. In BGE 140 II 167, the Federal Supreme Court answered this question with regard to persons subject to the FMPA who transfer their residence to a canton with lower taxation. After outlining the legal basis and discussing the above-mentioned Federal Supreme Court ruling, the author examines the question of how persons not subject to the FMPA are treated and what the (tax) consequences are if - in the opposite case - a natural person moves to a canton with a higher tax rate and is resident there at the end of the tax year.
Application of the most-favoured-nation clause according to the protocol of the double taxation agreement between Switzerland and India
In its communication of 13 August 2021, the State Secretariat for International Financial Matters (SIF) provides information on the changes to dividend taxation due to the application of the most-favoured-nation clause in the DTA CH-IN.
FTA publishes circular concerning professional expense allowances and remuneration in kind 2022
On 13 August 2021, the Federal Tax Administration (FTA) published the circular "Professional expenses lump sums and remuneration in kind 2022 / Compensation for the consequences of the cold progression in direct federal tax for the tax year 2022".
Federal Council adopts dispatch on new cross-border commuter agreement with Italy
At its meeting on 11 August 2021, the Federal Council adopted the dispatch on the new cross-border commuter agreement between Switzerland and Italy.
FDF - The reporting procedure for natural persons will not be pursued further
Based on the findings of a working group, the FDF decided on 5 August 2021 not to pursue the idea of a new reporting procedure for natural persons for withholding tax.
Consultation agreement between Switzerland and Germany
On 22 June 2021, Germany and Switzerland announced that the mutual agreement on the taxation of international workers would be extended until 30 September 2021. The parties will then consult again in due course.
Deduction for health insurance premiums to be increased
The Federal Council proposes to increase the deduction for compulsory health insurance and accident insurance premiums in direct federal tax.
Canton of Zurich - Adjustment of the information sheet on the granting of social deductions and the application of tax rates for families
The canton of Zurich has adapted the information sheet (ZStB No. 34.2) to the new legal calculation.
Mutual agreement between Switzerland and the USA on withholding tax exemption for pension plans
The Protocol of Amendment to the Double Taxation Treaty between Switzerland and the USA, which was approved on 17 July 2019, provides that dividends paid to tied pension institutions (e.g. pillar 3a) will be exempt from withholding tax from 1 January 2020, provided that they do not control the US company paying the dividends.
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"
