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.
ISIS seminar folder "Gratuitous transfer of assets under tax law"
All documents from the ISIS) seminar "Gratuitous transfer of assets in tax law" from October 28, 2025 under the direction of Peter Mäusli-Allenspach 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.
Practical examples of cross-border issues in relation to Germany
Case studies, slides and detailed solution notes from the workshop held by Hanna Brozzo and Iring Christopeit on October 28, 2025 on the occasion of the ISIS seminar "Gratuitous asset transfers in tax law".










