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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New Form 12 FL for the declaration of the insurance stamp by Liechtenstein policyholders
A new Form 12 FL concerning the self-declaration of stamp duty on insurance premiums / insurance with a foreign insurer by Liechtenstein policyholders was published on 9 July 2021.
Strengthening Switzerland as a business location in the context of OECD work
The Federal Council has taken note of the status of the OECD/G20 work on global corporate taxation.
Federal Council adopts dispatch on reform of withholding tax
The Federal Council wants to strengthen Switzerland as a location for the debt capital market and for group financing activities in all sectors.
FTA extends flat-rate taxation for the private use of business vehicles
On 17 March 2021, the FTA published the amendment to Art. 5a of the Professional Costs Ordinance. On the one hand, the current flat rate will be regulated in the Professional Costs Ordinance from 1 January 2022, and on the other hand, the flat rate will now take into account commuting costs and will be increased from 0.8% to 0.9% per month (or from 9.6% to 10.8% per year) for this purpose.
Federal Council opens consultation on tonnage tax
At its meeting on 24 February 2021, the Federal Council opened the consultation on the Federal Act on the Tonnage Tax on Sea-going Ships. An introduction in Swiss tax law would be a targeted means of ensuring the competitiveness of Switzerland as a business location in the area of maritime shipping companies.
Tax-approved interest rates 2021 for advances or loans in Swiss francs and foreign currencies
The granting of interest-free or insufficiently interest-bearing advances or loans to participants or third parties related to them constitutes a payment in kind. This shall also apply to translated interest which is paid on the basis of obligations to participants or third parties close to them.
FTA publishes notice on the taxation of non-cash expenses for collective investment schemes
In concretisation of Art. 14 StG, Circular No. 24 of the Federal Tax Administration (FTA) of 20 November 2017 on collective investment schemes as subject to withholding tax and stamp duties states that non-cash expenses in the form of taxable deeds by an FCP, a SICAV or a KmGK to the investor are not subject to turnover tax.
Circulars No. 9 and No. 16 of the FTA repealed
Circular No. 16 of the FTA of 13 July 2007 concerning "Inadmissibility of the tax deduction of bribes" and 1-009-DV-2005 of 22 June 2005 concerning "Proof of business-related expenses in foreign-foreign transactions" have both been repealed and replaced by Circular No. 50 of 13 July 2020.
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Transactions et restructurations - Partie 2
Atelier de Arthur Magnin à l'occasion du séminaire ISIS) du 7 novembre 2023 intitulé "Actualités en matière d'impôt anticipé / Droits de timbre"
Dossier de séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" (2023)
Etudes de cas, solutions détaillées et transparents : vous trouverez ici tous les documents des différents ateliers selon la description du contenu ci-dessous du séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" du 7 novembre 2023 sous la direction de Laila Rochat.
