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.
Remuneration/cost reimbursement vs. items in transit
Workshop on the occasion of the ISIS) seminar on 26 September 2019 entitled "Value Added Tax. Current. Compact. Interdisciplinary.".
Effects from current case law and administrative practice
Workshop on the occasion of the ISIS seminar of 26 September 2019 entitled "Value Added Tax. Current. Compact. Interdisciplinary.".
Possibilities and limits of corporate tax planning - national and international
Workshop on the occasion of the ISIS seminar on 9/10 September 2019 entitled "Tax planning in the area of conflict between cost optimisation, tax compliance and Good citizenship - opportunities and risks".
ISIS) seminar "Current Issues in Corporate Tax Law (Repetition)" (seminar folder)
Case studies, detailed solution notes and slides: Here you will receive all documents (workshops and presentations) according to the following description from the ISIS) seminar "Aktuelles zum Unternehmenssteuerrecht (Wiederholung)" from 03/04 June 2019 under the direction of Peter Mäusli-Allenspach, which took place in the Grand Resort in Bad Ragaz.
