Implementation of global minimum taxation - safe harbor transitional rules for investment entities
On January 1, 2024, Switzerland partially introduced the OECD minimum tax by means of the Minimum Tax Ordinance (MindStV). The implementation of the global legal requirements poses considerable challenges for companies due to the complexity of the regulations and the technical implementation in the accounting systems. For this reason, many companies fall back on safe harbor regulations provided by the OECD. In this context, the following article examines whether these also apply to investment entities that are part of the corporate group.
The valuation of participation rights in start-up companies and the principle of equal treatment
The tax valuation of start-ups has been the subject of debate in Switzerland. While a viable solution has been found for the shareholders of start-ups with the current solution, the question of an even wealth tax burden for shareholders in a comparable situation arises. Find out what challenges arise in the valuation of participation rights and what solutions are being discussed to ensure a balanced tax policy.
"Structure follows strategy" in corporate succession - insights from the SIX Swiss Exchange Family Business Conference 2023
"Structure follows strategy" is a conclusion of the American business historian Alfred D. Chandler, which states that the strategy should be defined first and then a structure that leads to the realization of the strategy. This principle is often not sufficiently taken into account in corporate succession and the focus is prematurely placed on implementation and structuring issues. The topics discussed at this year's SIX Swiss Exchange Family Business Conference are set out below against this background.
Succession planning: tax pitfalls
When Swiss families think about the organization of their estate, they generally do not pursue any immediate tax objectives. In general, it is more a question of transferring assets to the next generation or at least initiating the future reorganization of ownership structures in the present. Of course, reducing wealth tax and breaking the tax progression, for example, can be an accompanying motive, but practice shows that this is rarely the actual "trigger". This article presents some typical questions.
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.
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Parliament revises revised withholding tax law
With the revised Withholding Tax Act, claims should be able to be asserted retroactively only for proceedings that have not yet been legally concluded. On Thursday the National Council resolved this last difference with the Council of States.
Referendum as final hurdle for tax bill
The AHV tax deal stands. The Council of States has resolved the last differences. Tax bill 17 is thus ready for the final vote at the end of the autumn session.
Tax bill 17 - Councils agree
The councils are in agreement on tax bill 17, and the last differences regarding the municipal article and the capital contribution principle have been resolved. An overview of the most important key points regarding tax submission 17:
Tax bill 17 - the WAK-N on course for the Council of States
The Committee for Economic Affairs and Taxes of the National Council (WAK-N) has begun detailed consultations on tax bill 17 (18,031) and has taken decisions on a number of key issues. So far, it has followed the Council of States in all points, including social compensation via the AHV and dividend taxation. The detailed discussion will be concluded at the meeting on 3 September.
Tax deductibility of fines under certain conditions
For the second time, the WAK-N dealt with the tax treatment of financial penalties (16,076). It proposes by 13 votes to 12 that fines and penalties imposed abroad should be tax deductible under certain conditions.
WAK-S: Withholding tax
The commission agreed by 6 votes to 4 with 1 abstention to the decision to follow the commission initiative of its National Council sister commission 17,494.
Federal Council adopts dispatch on the BEPS Convention
On 22 August 2018, the Federal Council adopted the dispatch on the multilateral agreement on the implementation of measures to prevent base erosion and profit shifting (BEPS). The message was referred to the Federal Councils.
New VAT regulation Online shopping abroad could become more expensive from 2019
The Federal Council has decided that mail order companies with a turnover of at least CHF 100,000 in Switzerland must pay VAT. Foreign online merchants today do not have to pay VAT on small consignments with a tax amount of less than five francs. For Swiss mail order companies, however, different rules apply: The consignments are subject to VAT if the company is entered in the VAT register. From 1 January 2019, this unequal treatment will cease.
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Trust et trustees: Obligations en matière de droit de timbre de négociation / Quelques aspects d'impôt anticipé en matière de trusts et fondations
Workshop by Laïla Rochat and Emilia Rebetez on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
Questions choisies d'impôts directs, droits de donation et succession
Workshop by Nicolas Candaux and Arnaud Cywie on the occasion of the ISIS) seminar of November 16, 2022 entitled "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation".
Seminar folder ISIS)-Seminar "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation" (2022)
Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following DeepL description from the ISIS) seminar "Structuration du patrimoine privé au moyen d'un trust ou d'une fondation" of November 16, 2022 under the direction of Laïla Rochat.
