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.
Deductibility of fines and penalties
In its decision of 26 September 2016, the Federal Supreme Court had to rule on a case concerning the tax law admissibility of a provision in connection with an EU cartel fine. The affected X. AG filed an appeal against the decision of the Cantonal Tax Office of Zurich with the Tax Appeal Court of the Canton of Zurich, which upheld the appeal. The cantonal tax office appealed unsuccessfully against this decision to the Administrative Court of the Canton of Zurich, which dismissed the appeal in its ruling of 9 July 2014 on both state and municipal taxes and direct federal taxes. The cantonal tax office then lodged an appeal with the Federal Supreme Court in matters of public law.
Tax issues with SPAs and Warranty & Indemnity insurance policies
Workshop by Susanne Schreiber and Susanne Liebel-Kotz on the occasion of the ISIS) seminar on 05 April 2022 entitled "Current tax issues in national and international M&A transactions".
Current cases in the taxation of legal entities as buyers and sellers
Workshop by Gernot Zitter and Claudia Schaub on the occasion of the ISIS) seminar on 05 April 2022 entitled "Current tax issues in national and international M&A transactions".
Fiscal perspective
Workshop by Ruth Bloch-Riemer and Toni Hess on the occasion of the ISIS) seminar on 09 November 2021 entitled "Freelance work: tax, social security and pension law aspects".
Seminar folder ISIS)-Seminar "Restructurations / Mergers / Acquisitions" (2021)
Case studies, detailed solutions and slides: Here you will find all documents of the individual workshops according to the following description from the ISIS seminar "Restructurations / Mergers / Acquisitions" of 3 November 2021, which was held in Lausanne under the direction of Laïla Rochat.
