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.
FTA - Circular on professional expense allowances and remuneration in kind 2024 / Compensation for the consequences of the cold progression in direct federal tax for the tax year 2024
On September 5, 2023, the FTA published the circular "Professional expenses lump sums and remuneration in kind 2024 / Compensation of the consequences of the cold progression in the direct federal tax for the tax year 2024".
Federal Council sets benchmarks for individual taxation
At its meeting on August 30, 2023, the Federal Council defined the key parameters for the dispatch on the introduction of individual taxation. This bill will also serve as an indirect counter-proposal to the popular initiative "For individual taxation independent of civil status (tax fairness initiative)".
Cross-border commuter agreement with Italy has entered into force
On July 19, 2023, SIF announced that the new cross-border commuter agreement with Italy and an amending protocol to the DTA entered into force on July 17, 2023. The provisions are applicable as of January 1, 2024.
Consultation agreement between Switzerland and Germany
The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
FTA - Life annuities will be taxed flexibly as of 2025
The taxation of life annuities in pillar 3b will be flexibly adjusted to the investment conditions when it comes into force on January 1, 2025.
Consultation agreement between Switzerland and Germany concerning withholding taxes
The State Secretariat for International Financial Matters SIF announces that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the procedure for relief from German withholding taxes on dividends, interest and royalties under the double taxation agreement between Switzerland and Germany.
Accrual and deferral of profit and income from real estate held as business and private assets (in particular sale and realisation transactions), taxation of rent and imputed rental value as well as ground rent
ISIS) seminar on 11-12 September 2017 - Accrual and deferral of profit and income from real estate held as business and private assets (in particular sale and realisation transactions), taxation of rent and imputed rental value and of ground rent
Determination of the real estate gain of real estate of private assets as well as problems of taxation of the real estate gain in case of gift, advance withdrawal of inheritance and inheritance
ISIS) seminar on 11 September 2017
