Automatic exchange of information and (unpunished) voluntary declarations
Since 1 January 2010, taxpayers in Switzerland have been able to go unpunished when they report tax evasion for the first time. Since then, tax transparency has increased internationally. Switzerland is pursuing the approach of implementing the international minimum standards. This now also includes the automatic exchange of information. On the way to a transparent taxpayer, the question arises as to whether the possibility still exists or should exist for taxpayers to disclose previously untaxed assets without having to expect a fine.
"Mother-daughter" arrangement between Italy and Switzerland
Opinion No. 537 of 6 August 2021 of the Italian tax authorities, described in this article, is a further sign of the "normalisation" of income tax relations between Italy and Switzerland.
Implementation of the tax reform and AHV financing (STAF) in the canton of Solothurn and first practical experiences
With the adoption of the STAF by the Swiss electorate on 19 May 2019, the cantonal tax privileges were abolished in all cantons as of 1 January 2020 and replaced by instruments that are internationally accepted. While the Solothurn electorate approved the STAF at federal level with 58.6% of the vote, it simultaneously rejected the first cantonal proposal to implement the STAF, which would have provided for a significant reduction in the profit tax rate, with 51.4% of the vote. In the second proposal, which was accepted by the electorate, it was possible to agree on a less extensive, but still substantial, reduction of the profit tax rate. For the city of Solothurn, for example, the effective profit tax rate for legal entities will be 15.29% from 2022 (previously: 21.23%). In addition to this reduction in the profit tax rate and the legislative changes prescribed by the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Municipalities (StHG), individual provisions of the Tax Act were adapted to the new accounting law with the implementation of the STAF in the Canton of Solothurn and accompanying measures were adopted in the area of natural persons.
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.
.jpg)
.jpg)
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.
Simultaneous dividend booking in group relationships
The Swiss Accounting and Reporting Manual allows a domestic parent company to recognize the investment income of its subsidiary (i.e. its dividend declared in financial year n+1) as income on a deferred basis in the financial year in which the subsidiary earned it. If the parent company makes the final booking of this income to the income statement at the time of distribution of the dividend, this constitutes proper booking for the purposes of the refund of the withholding tax and for the implementation of the reporting procedure.
Tax template 17 is linked to AHV restructuring
Tax Bill 17 will be linked to the AHV restructuring. This was decided by the Council of States. This approach is intended to help the corporate tax reform achieve a breakthrough and relieve the burden on old-age pensions.
Withholding tax refund despite non-declaration in the tax return - National Council vote
Anyone who has not declared income in the tax return should still receive the withholding tax back if he has been negligent. The National Council has approved this change, but wants to go considerably further than the Federal Council.
Tax submission 17 (12 April 2018)
The Committee for Economic Affairs and Taxes of the Council of States (WAK-S) has already unanimously agreed to tax bill 17 at its meeting on 12 April 2018. At its meeting on 15 May 2018, the WAK-S unanimously supported an overall concept with the following four central elements:
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.
.jpg)
Harmonisation efforts of the circular no. 45 in the area of withholding tax
Workshop by Jennifer Herren, Dirk Hangarter and Patrick Meier on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
Quasi-residency and comparable circumstances
Workshop by Jennifer Herren, Dirk Hangarter and Patrick Meier on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
Seminar folder ISIS)-Seminar "Withholding Tax: Selected Case Constellations" (2021)
Case studies, detailed solution notes and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS) seminar "Withholding tax: Selected case constellations" of 31 August 2021 under the direction of Martin Huber, which took place in Zurich.
