Reform of the withholding tax - can the Gordian knot be untangled?
With its dispatch of April 2021 on the reform of the withholding tax, the Federal Council is making a new attempt to strengthen the domestic debt capital market. The bill is economically necessary and suitable for finding a pragmatic solution that is acceptable to the majority. Parliamentary consultations have already begun.
Withholding tax and debt capital, including the planned revision of the Withholding Tax Act
In terms of withholding tax, we focus on withholding tax on the income from equity securities. In particular, pecuniary benefits occupy us and often lead to emotionally profound experiences and contacts with withholding tax. Similarly, we constantly deal with the question of the refund of withholding tax owed, including the issue of "How can I repatriate profit reserves subject to withholding tax abroad?
Withholding tax reform - "more than meets the eye
The withholding tax reform bill introduced with the Federal Council Dispatch published on 14 April 2021 aims to largely abolish withholding tax on interest income and, as an accompanying measure, to abolish the turnover tax on Swiss bonds. In this context, implementation issues at the banks and financial institutions, the effects of the reform on structured products and group financing, the treatment of substitute payments in securities lending/borrowing transactions and indirect interest investments are examined in greater detail.
Editorial for the special issue "Implementation of the STAF
At zsis we are pleased to be able to provide an overview of the implementation of the corporate tax reform in the individual cantons. The authors not only provide information on the reduction of the profit tax rate, but also highlight the change from tax privileges to ordinary corporate taxation. They also report on the other cantonal particularities.
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Federal Council adopts dispatch on the amendment of the double taxation agreement with Armenia
The Federal Council adopted the dispatch on the Protocol of Amendment to the DTA on 4 May 2022.
Federal Council adopts dispatch on DTA with Ethiopia
On 18 March 2022, the Federal Council adopted the dispatch on the DTA with Ethiopia. With this DTA, Switzerland is extending its network of agreements to East Africa for the first time.
FTA publishes legislative and ordinance amendments 2023-2025
The FTA has published the list of pending legislative and ordinance amendments for direct federal tax, VAT, withholding tax and stamp duties 2023-2025.
Proposals for the introduction of a Swiss trust
On behalf of Parliament (Motion 18.3383), the Federal Council proposes the introduction of a new legal institution in the Code of Obligations. On 12 January 2022, it opened the consultation regarding the introduction of a Swiss trust, which will last until 30 April 2022.
FTA publishes legislative and ordinance amendments 2022-2024
The FTA has updated the lists of legislative and ordinance amendments in the area of direct federal tax, value added tax, withholding tax and stamp duties.
Federal Council responds to various tax proposals
At its meeting on 17 November, the Federal Council responded to various tax-related requests (see also the related FTA post):
Federal law on electronic procedures in the tax area enters into force in a staggered manner
The Federal Act on Electronic Procedures in Tax Matters regulates electronic procedures in all tax areas. For its implementation, the Federal Council decided in November on a staggered entry into force.
Federal Council enacts new legal basis for the implementation of international agreements in the tax area
In the StADG, the provisions of the existing national federal law of 22 June 1951 on the implementation of federal intergovernmental agreements for the avoidance of double taxation and the ordinances based on it are taken over as far as necessary and supplemented with new provisions. It now regulates the essential points for the relief of withholding tax as well as penalty provisions in connection with the relief of withholding taxes on investment income. It also regulates how mutual agreement procedures are to be carried out domestically if the applicable agreement does not contain any provisions to the contrary.
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