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.
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.
