Taxation of compensation payments from share certificates
This paper focuses on the income tax treatment of income from investments in classical index and basket certificates from equities. The focus is on the view of the investor resident in Switzerland who holds the products as part of her private assets.
The Liechtenstein private law establishment with divided or undivided capital
The Liechtenstein private law establishment is a very versatile and flexible legal form which is unknown under Swiss company law and cannot generally be assigned to corporations or foundations. The article deals with the "establishment" as a special feature of Liechtenstein company law.
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".
Tax rulings - Swiss success model at risk?
Tax rulings are omnipresent in Swiss tax consulting. With the StAhiV, they have been incorporated into Swiss legislation for the first time as of 1 January 2017 and are referred to there as "preliminary tax assessments", about which other states must be informed in certain situations. Recently, the courts have also been increasingly concerned with questions relating to tax rulings.
Compensation paid by Swiss companies to foreign directors
This video provides information on the possible tax and social security implications of a board of directors resident in an EU country in the case of a Swiss company limited by shares if the board of directors is also self-employed in its country of residence.
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Federal Council enacts Federal Act on the Taxation of Telework as of 1.1.2025.
At its meeting on October 16, 2024, the Federal Council decided to bring the Federal Act on the Taxation of Teleworking into force on January 1, 2025.
New circular no. 6a: Hidden equity capital
On October 10, 2024, the FTA published the updated circular no. 6a regarding "Hidden equity".
Taxes in the cost-plus method - FTA publishes statement on the ruling of the Federal Supreme Court 9C_37/2023
In its ruling 9C_37/2023 of June 11, 2024 (see our article), the Federal Supreme Court addressed, among other things, the question of whether or not the tax expense should be taken into account in the cost base when applying the cost-plus method in the context of Art. 58 para. 3 DBG.
FTA - Notification withholding tax: Declaration of reserves from capital contributions
On September 18, 2024, the FTA clarified the administrative practice in accordance with item 9 of circular no. 29c on the capital contribution principle dated December 23, 2023 regarding the declaration of reserves from capital contributions.
International supplementary tax IIR to come into force in 2025
At its meeting on September 4, 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force on January 1, 2025. In addition to the QDMTT, which was already introduced on January 1, 2024, this rule is intended to ensure that tax revenue remains in Switzerland.
Transitional solution for the too-big-to-fail instruments for withholding tax
At its meeting on August 21, 2024, the Federal Council approved a temporary extension of the special regulations for interest from TBTF instruments until December 31, 2031. Without an additional extension, interest on TBTF instruments issued after December 31, 2026 would be subject to withholding tax.
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Individual questions on the patent box
Workshop by Annette Walk, Alfred Köpf and Armin Marti at the ISIS) seminar on 21 September 2021 entitled "Status change, patent box and R&D effort in practice".
Individual questions on the additional deduction for research and development expenses
Workshop by Fabian Utzinger and René Matteotti at the ISIS) seminar on 21 September 2021 entitled "Status change, patent box and R&D effort in practice".
Seminar folder ISIS)-Seminar "Change of Status, Patent Box and R&D Effort in Practice" (2021)
Case studies, detailed solutions and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS seminar "Status change, patent box and R&D expenditure in practice" on 21 September 2021 under the direction of René Matteotti and Jürg B. Altorfer.
