Tax evasion and withholding tax
Whether a tax evasion has been committed negligently or intentionally has a decisive influence on the possibilities of refunding withholding taxes. With a view to a case study, this article discusses the points of contact between tax evasion in the case of direct taxes and the questions concerning the refund of withholding taxes under Art. 23 ITA.
Accounting in criminal tax law
While the annual financial statement that complies with commercial law is decisive for taxation in accordance with the law, criminal tax law is linked to the annual financial statement that does not comply with commercial law. Since Swiss criminal tax law lacks an overall concept and the criminal tax provisions are contained in the individual tax laws, the prosecution of which is incumbent on different authorities, the use of accounting that contains irregularities can lead to a multitude of non-coordinated criminal tax proceedings and tax penalties.
Tax offences as predicate offences to money laundering - Key takeaways for practitioners
Art. 305bis(1bis) of the Swiss Criminal Code entered into force on 1 January 2016, introducing aggravated tax misdemeanours as predicate offences to money laundering. Though highly debated at the time of its introduction, courts have been noticeably quiet on this provision in the years that followed. This article will analyse the developments since its adoption, outline the legal questions remaining open and forecast what the future may hold for this provision.
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.
Martin Huber about the new zsis)
The journal zsis) was renamed the "Center for Swiss and International Tax Law" in spring 2018. On the zsis)-platform, contents around the topic tax law are published. The publication takes place in 10 issues per year, which are sent directly and conveniently to your mailbox via a newsletter. All content distributed via the newsletter can also be found directly on the zsis)-platform.
OECD publishes report on Amount B of Pillar I
On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS published the report on Amount B of Pillar I.
Tax-recognized interest rates 2024 for advances or loans in Swiss francs and foreign currencies
On 29/30 January 2024, the FTA published the circulars on the tax-recognized interest rates in Swiss francs and foreign currencies 2024.
Cross-border commuter agreement with Italy: FTA publishes list of municipalities from 2024
On January 19, 2024, the FTA published the list of Italian municipalities within the meaning of Art. 2 of the cross-border commuter agreement with Italy, valid from January 1, 2024.
FTA - Imputed interest rate on the security equity
The imputed interest rate on the security equity corresponds to the yield on ten-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period in accordance with Article 25abis paragraph 4 first sentence StHG.
Memorandum of Understanding between Switzerland and Italy - List of municipalities
On December 22, 2023, the SIF reported that the list of Swiss and Italian municipalities whose territory lies wholly or partly within a 20 km zone on the border with the other contracting state was set out in a mutual agreement.
Federal Council decides to abolish tax exemption on electric vehicles
From 1 January 2024, electric cars will be subject to car tax. At its meeting on 8 November 2023, the Federal Council took note of the results of the consultation and approved the amendment to the Motor Tax Ordinance.
FTA publishes interest rates for direct federal tax 2024
The Federal Department of Finance is adjusting the refund and default interest rates for federal taxes and levies to the increased interest rate level. From 2024, an interest rate of 4.75 percent will apply in the case of arrears and for refunds. The interest rate on voluntary advance payments is now 1.25 percent.
Intellectual property rights
Workshop by Nathanael Zahnd and Balthasar Denger on the occasion of the ISIS) seminar on February 05, 2025 entitled "Intellectual property rights"
Investments in crypto assets
Workshop by Silvan Guler and Daniel Bürki on the occasion of the ISIS) seminar on September 23-24, 2024 entitled "Investments in crypto assets"
