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.
.jpg)
.jpg)
FTA publishes circular no. 32a: Reorganization of corporations and cooperatives
On January 20, 2025, the FTA published circular no. 32a regarding the "Restructuring of corporations and cooperatives".
FTA publishes imputed interest rate on the security equity 2025
The imputed interest rate on the security equity corresponds to the yield on ten-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period in accordance with Article 25abis paragraph 4 first sentence StHG.
Federal Council adopts dispatch on the extension of loss offsetting
On November 27, 2024, the Federal Council adopted the dispatch on extending loss offsetting from seven to ten years.
Practical specifications for sales tax for brokerage activities within a group relationship
Recent case law in the area of sales tax for intermediaries in a group relationship has prompted the FTA to make clarifications in its administrative practice regarding Art. 13 para. 1 and Art. 13 para. 3 lit. b no. 2 StG. The two practical clarifications will be applied with immediate effect and will apply to all cases currently pending with the FTA.
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.
.jpg)
Income tax and social security aspects of corporate restructuring
Workshop on "Income Tax and Social Security Aspects of Corporate Restructuring" by Tabea Nyfeler and Severine Vogel on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 2023.
Cross-border restructuring
Workshop on "Cross-border Restructuring" by Patrick Schmid and Thomas Hug on the occasion of the ISIS seminar "Corporate Restructuring" on August 29, 2023.
