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.
Reporting concerning tax relief within the framework of regional policy
According to a media release, at its meeting on February 1, 2023, the Federal Council took note of a report by the Federal Department of Economic Affairs, Education and Research (EAER) on defining the areas of application for tax relief under regional policy.
FTA announces imputed interest rate on security equity 2023
On January 4, 2023, the FTA announced that the imputed interest rate on the security equity pursuant to the first sentence of Article 25abis(4) of the Tax Act, which is equal to the yield on 10-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period, is 1.565% for the 2023 tax year.
VST: Changes from January 1, 2023 in the reporting procedure in the group relationship
According to a communication from the Federal Tax Administration (FTA) dated December 23, 2022, the scope of the reporting procedure will be expanded as of January 1, 2023.
FTA publishes circular no. 29c "Capital contribution principle
The FTA published Circular No. 29c "Capital Contribution Principle" on December 23, 2022.
FTA publishes tax statistics for individuals and legal entities 2019
On November 3, 2022, the FTA published the 2019 tax statistics.
FTA publishes interest rates for direct federal tax 2023
On October 13, 2022, the Federal Tax Administration (FTA) published the - unchanged - interest rates for the 2023 direct federal tax:
Update of the areas of application for tax relief
On October 10, 2022, the Federal Department of Economic Affairs, Education and Research (EAER) adopted an amendment to the "Ordinance of the EAER on the Determination of the Municipalities Included in the Areas of Application for Tax Relief" for the purpose of updating the areas of application for tax relief under regional policy.
Reporting procedure in group relationships and restitution in national relationships - current practice, decisions and innovations
Workshop by Markus Küpfer on the occasion of the ISIS) seminar on August 30, 2022, entitled "Reporting procedures in group relationships and restitution in national relationships - current practice, decisions and innovations".
Criminal withholding tax law - practical cases and outlook
Workshop by Daniel Holenstein on the occasion of the ISIS) seminar on August 30, 2022, entitled "Criminal withholding tax law - practical cases and outlook".
Taxation of intangible assets from the perspective of partnerships and SMEs
Workshop by Gian Andrea Rusca and Daniel Strahm on the occasion of the ISIS) seminar on 27 June 2022 entitled "Taxation of intangible assets from the perspective of personal companies and SMEs".
Seminar folder ISIS)-Seminar "Tax and Duty Treatment of Intellectual Property Rights
Case studies, detailed solution notes and slides: Here you will find all the documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Tax and tax law treatment of intellectual property rights" of 27 June 2022 under the direction of René Schreiber.
