Refund of withholding tax in the case of a domestic permanent establishment with a foreign parent company - the "permanent establishment sandwich" for withholding tax purposes
Judgment of the Federal Supreme Court of 22 February 2008 on the question of the entitlement of the domestic permanent establishment of a foreign parent company to a refund of withholding tax Proceedings 2C_333/2007 and 2C_407/2007 (published in StR 2008, p. 475)
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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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tariffs for calculating the maximum amount up to which a flat-rate tax credit can be granted to natural persons was repealed.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.
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ISIS)-Seminar folder "Taxation of shareholder and company in personal companies" (2023)
Case studies, detailed solution notes and slides: Here you will receive all documents of the individual workshops according to the following content description from the ISIS)-Seminar "Taxation of Shareholder and Company at Personally Owned Businesses" from September 18 - 19, 2023 under the direction of Andrea Opel.
Social security aspects in personal companies
Workshop on "Social Security Aspects in Personally Owned Companies" by Petra Caminada and Moritz Seiler on the occasion of the ISIS seminar "Taxation of Shareholder and Company in Personally Owned Companies", September 18-19, 2023.
Reclassification of capital gain as taxable capital income
Workshop on "Reclassification of capital gain from sale into taxable capital gain" by Thomas Wolfensberger and Marco Buchmann on the occasion of the ISIS seminar "Taxation of Shareholder and Company in Personally Owned Businesses" on September 18 - 19, 2023.
