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.
OECD publishes statement on taxation of multinational companies
On 31 January 2020, the Organisation for Economic Cooperation and Development (OECD) published a statement on taxation of multinational (digital) companies, according to which an agreement should be in place by the end of 2020 (see also taxlawblog contributions of 12 October 2019 and 9 November 2019).
SIF updates list of DTAs with abuse provisions
On 17 January 2020, the Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) updated the list of agreements with abuse provisions.
Canton ZH: Changes to the flat-rate tax credit
The ordinance on the implementation of the flat-rate tax credit was adapted to the new requirements of federal law as of 1 January 2020. On the same date, the Ordinance on cantonal tariffs for calculating the maximum amount up to which a flat-rate tax credit can be granted to natural persons was repealed.
Online refund application of withholding tax for persons resident in Germany
An online application of the Swiss Federal Tax Administration (FTA) will be available for refund applications for Swiss withholding tax by German residents from 31 January 2020.
The Swiss Federal Tax Administration has published Circular Letter No. 29b "Capital Contribution Principle
On 23 December 2019, the Swiss Federal Tax Administration published Circular Letter No. 29b "Capital Contribution Principle". Circular Letter No. 29b comes into force on 1 January 2020 and replaces the previous circular letters No. 29 and 29a.
Implementation of STAF: Regulations enter into force on 1 January 2020
At its meeting on 13 November 2019, the Federal Council approved three ordinances on the Federal Tax Reform and OASI Financing Act (STAF). These amendments concerning the tax part will enter into force on 1 January 2020.
WAK of the National Council for the abolition of the turnover tax and the insurance tax or reform of the withholding tax
In its media release of 5 November 2019, the National Council's WAK provided information on the parliamentary initiative on turnover tax and insurance tax, on the reform of withholding tax and on the neutrality of legal forms in corporate taxation.