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.
Reasons for mitigation in post-tax and fine proceedings
Swiss criminal tax law may impose different penalties for the same offenses. This is due to statutory grounds for mitigating penalties, which ensure that personal circumstances and individual cases can be taken into account. The aim of this article is to provide an overview of the grounds for mitigating penalties in post-tax proceedings and to highlight current developments in practice, particularly in the Canton of Zurich.
Cross-border commuter regulation Switzerland-France
The home office has fundamentally changed cross-border taxation - also in the relationship between Switzerland and France. New rules have applied to French cross-border commuters since 2023, which allow more flexibility but also place greater demands on employers and employees. This article provides a concise overview of the current tax framework and shows what should be paid particular attention to.
Taxation of spouses in international relationships - Federal Supreme Court ruling of September 23, 2024 Prejudice on tax separation issues
In its ruling of September 23, 2024, the Federal Supreme Court issued a long-awaited precedent on the issue of international tax differentiation of debts and debt interest in the case of international spouses and revised its ruling of March 2023 on the international transfer of maintenance payments to the divorced spouse. What does this precedent mean for practice and how should other exciting practical cases be handled?
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.
Federal Council opens consultation for new regulation of professional costs
At its meeting on December 21, 2022, the Federal Council opened the consultation process for a new regulation of professional costs.
Asset structuring through trusts and foundations
Workshop by Andrea Opel and Andrea Hildebrand on the occasion of the ISIS seminar from 23 - 24 September 2024 entitled "Asset structuring using trusts and foundations"
Investments in real estate (national/international)
Workshop by Laetitia Fracheboud and Olivier Margraf on the occasion of the ISIS seminar from 23 to 24 September 2024 entitled «Investments in real estate (national/international)»
