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.
FTA publishes working paper on cryptocurrencies and ICOs/ITOs
The emergence and spread of crypto-currencies have raised various questions about the tax treatment of these book-entry securities. The Swiss Federal Tax Administration (FTA) has published a working paper outlining the practice developed to date (status end of May 2019).
Bundesrat approves key points of a reform of the withholding tax
On 26 June 2019, the Federal Council decided to resume the suspended reform of the withholding tax. To this end, it approved the objectives and the key parameters.
STAF enters into force on 1 January 2020
According to a press release dated 14 June 2019, the Federal Law on Tax Reform and OASI Financing (STAF) will come fully into force on 1 January 2020.
STAF - Abolition of the federal practices for principal companies and Swiss Finance Branches
As part of the implementation of the STAF, the Federal Tax Administration (FTA) will no longer apply the federal practices for principal companies and Swiss Finance Branches from 1 January 2020.
Adoption of the tax reform and AHV financing (STAF) (referendum of 19 May 2019)
After the Corporate Tax Reform III (USR III) was rejected in February 2017, Swiss voters voted on the tax reform and AHV financing (STAF). The proposal was accepted by the people and cantons with around 66% (cf. preliminary official final results).
Clarification of legal information and preliminary tax assessments (tax rulings)
On 29 April 2019, the Federal Tax Administration (FTA) published details of the code of conduct for the provision of legal information and rulings in the areas of value added tax and corporate tax for radio and TV as well as tax rulings for direct federal tax, withholding tax and stamp duties.
FDK publishes survey results on the implementation status of STAF in the cantons
The Conference of Cantonal Finance Directors (FDK) published the results of a survey on the updated implementation status of the Federal Law on Tax Reform and OASI Financing (SV17 / STAF) in a communication dated 10 May 2019.
Focus on procedural law
Workshop by Thomas Jaussi on the occasion of the ISIS) seminar on October 21, 2024 entitled "Focus on procedural law"
Reporting procedure in group relationships, reimbursement in national relationships - current practice and rulings
Workshop by Markus Küpfer at the ISIS) seminar on October 21, 2024 entitled "Reporting procedures in group relationships, reimbursement in national relationships - current practice and decisions"
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Criminal withholding tax law - liability risks for directors and trustees/statute of limitations/intent
Workshop by Daniel Holenstein on the occasion of the ISIS) seminar on October 21, 2024 entitled "Criminal withholding tax law - liability risks for board members and trustees/statute of limitations/intent"